Serving the Borrower Who Applied in Spanish: Limited-English-Proficiency Mortgage Origination With AI, the CFPB Line, and Where a Translated Disclosure Becomes a Liability
AI voice and chat agents make it cheap to talk to a borrower in their language, which is exactly why the risk moves from access to accuracy. Where ECOA and the UDAAP standard still draw the line after the CFPB pulled back its 2021 guidance, why we run the conversation in the borrower's language but keep the operative disclosures in English, and the translation-QA control that stops a servicing term from drifting in the second language.