Access to Capital

Lending

Village Capital was founded in 1992 and is a AERIS-rated, certified Community Development Financial Institution with the U.S. Department of Treasury’s Community Development Financial Institutions Fund. Village Capital’s objective is to approve financing for catalytic projects that have community support and that advance the strategic efforts of a community.

Village Capital is strong community partner that brings local expertise and financing assistance to high profile and challenging development projects. Village Capital finances market-rate and affordable residential, commercial, retail, industrial, as well as mixed-use real estate projects in Northeast Ohio. Village Capital primarily provides pre-development, acquisition, construction and mini-perm loan facilities to its borrowers, both for-profit and non-profit.

Over our history, Village Capital has provided over $65 million in loans to support over $873 million in total development costs for more than 200 separate real estate projects. Village Capital’s financing activities have helped to create and preserve over 7,400 residential units and more than 1.7 million square feet of commercial space.

For more information, contact Dione Alexander, President at 216.453.1454 or DAlexander@ClevelandNP.org

VCC Investors and Supporters

The Cleveland Foundation
Enterprise Community Loan Fund
The George Gund Foundation
Huntington Bank
US Bank
U.S. Department of Treasury’s CDFI Fund
Cleveland Development Advisors
PNC Bank
Fifth Third Bank
Dollar Bank
J.P. Morgan Chase Foundation

Language Access Plan (LAP) for VCC

Introduction and Purpose

In compliance with Title VI of the Civil Rights Act of 1964 and Executive Order 13166, “Improving Access to Services for Persons with Limited English Proficiency”, Village Capital Corporation (“VCC”), a Community Development Financial Institution (“CDFI”) as certified by the U.S. Department of Treasury Community Development Financial Institutions Fund, has established the following LAP. The purpose of the LAP is to ensure that individuals with limited English proficiency (LEP) may access all resources and services provided by VCC. An “LEP individual” is defined as “an individual who does not speak English as their primary language and who has a limited ability to read, speak, write, or understand English.”1

This plan establishes strategies for interacting with and providing services to LEP individuals in order to ensure equity and inclusion across beneficiaries. This is essential to our mission of investing in the revitalization of under-resourced communities in northeast Ohio. To prepare for the development of this plan, we conducted a Four-Factor Analysis which balanced the following factors:

1. The number or proportion of LEP persons served or encountered in the eligible service population;

2. The frequency with which the LEP persons come into contact with the agency;

3. The nature and importance of the program, activity, or service provided by VCC; and

4. The resources available and costs to the recipient.

Persons Charged with Implementing the Plan

The President of VCC will be responsible for overseeing the implementation of this plan. In addition to their oversight duties, the President will be charged with maintaining and updating this plan as the need for changes arises. The President will report to the Board of Directors of VCC regarding changes to this plan and will coordinate with appropriate federal state, and local agencies in order to carry out the directives established by this plan.

Identification and Assessment of LEP Communities

In order to identify LEP individuals in our service area, we consulted data from the United States Census Bureau. Based upon this data, we have identified the LEP population(s) in Cleveland, OH to be persons who speak Spanish at home (8.7% of population). Individuals that speak English at home account for 85.9% of the population while individuals that speak neither English or Spanish at home account for 5.4% of the population and represent three discrete language classifications. As our community evolves over time, we will continue to monitor shifts in our population’s demographics to ensure that we are adequately tracking LEP representation in our service area. We will also work to identify LEP individuals in our normal encounters with the public by:

• Responding to individual requests for language assistance services;

• Relying on self-identification by the non-English speaker or LEP individual;

• Asking open-ended questions to determine language proficiency

Language Assistance Services

It is our understanding that LEP individuals may interact with our staff in a number of ways to include but not limited to:

• Participation in training or technical assistance programs;

• Submission of applications for financial assistance;

• Access to written materials, brochures, or websites associated with VCC.

Due to the variety of encounters that LEP individuals may have with VCC, a variety of language assistance services will be provided and advertised to these individuals. To determine the extent of language assistance services provided, we relied on our Four-Factor Analysis and identified the following group(s) as meeting the 5% LEP threshold for the provision of language assistance services: Spanish language (8.7 % of population). For this LEP population, both oral and written language assistance services will be provided.

Oral Language Assistance

Oral language assistance may be necessitated by encounters with LEP individuals either over the phone or in person. When one of these encounters occurs, staff members will carry out the following protocol:

For communication over the phone:

The staff member will first make an effort to identify the primary language of the individual. If that staff member is approved as bilingual in the individual’s primary language by VCC (or its parent company, Cleveland Neighborhood Progress), then that staff member may assist the LEP individual directly. If the staff member has not been approved as bilingual in that language, then that staff member will transfer the call to another staff member who has been approved as bilingual. If no bilingual staff member is available to assist the individual, then a (telephone language translation service (e.g., 3-1-1 service); approved volunteer from the community; interpreter for hire; etc.) may be used to communicate with the LEP individual.

For communication in person:

The staff member will first make an effort to identify the primary language of the individual. If that staff member is approved as bilingual in the individual’s primary language by the agency, then that staff member may assist the LEP individual directly. If the staff member has not been approved as bilingual in that language, then that staff member will contact another staff member who has been approved as bilingual by VCC (or its parent company, Cleveland Neighborhood Progress), to come and assist the individual. If no bilingual staff member is available to assist the individual, then a (telephone language translation service (e.g., 3-1-1 service); approved volunteer from the community; interpreter for hire; etc.) may be used to communicate with the LEP individual.

Written Language Assistance

Written language assistance may be necessitated for certain “vital documents”. Documents classified as “vital” include those that are deemed necessary for individuals or corporate entities to obtain financial services from VCC and to legally bind those individuals or corporate entities to agreements (e.g. loan agreements or promissory notes) made with VCC. Documents not considered vital will be available for oral or written translation upon request.

Guidelines for Interpreters and Translators

While no formal certification is required for interpreters, translators, or staff members designated as bilingual, individuals providing interpretation or translation services must:

• Be proficient in and able to communicate information accurately in both English and the other applicable language;

• Understand business and or lending-specific terminology;

• Act in an ethical manner and ensure confidentiality and impartiality in their role as an interpreter/translator;

• Be aware of regionalisms and be able to provide the most appropriate interpretation in a consistent manner.

LEP individuals may bring another individual to provide interpretation who has not been approved for formal interpretation services by the agency. During these encounters, staff will:

• Inform the LEP individual that free language assistance services are provided;

• Use a formal interpreter instead of the informal interpreter, especially if the subject matter of the encounter may be prone to conflicts of interest;

• Avoid the use of minors as informal interpreters unless there is an extreme and immediate need.

When working with an interpreter, formal or informal, VCC staff should:

• Explain to the interpreter the purpose of the communication and the information to be conveyed;

• Briefly explain to the interpreter technical terms that may come up during the communication;

• Speak in short sentences that contain one idea at a time;

• Talk to the applicant and not to the interpreter;

• Enunciate clearly and wait for the interpreter to finish before continuing to the next idea.

Providing Notice of Language Assistance Services

To ensure that members of LEP communities are aware of the free language assistance services provided to them, the following marketing and outreach steps will be taken:

• Distribute translated materials to community organizations that explain how to access language assistance services;

• Provide notification of services with (application, certification, marketing, other) materials.

Training Staff on LEP Policies and Services

All VCC staff will receive training on the importance of providing meaningful information and services to LEP individuals in a way that they can understand. This training will be included as new employee onboarding and refresher training will be provided periodically at staff meetings. After completion of the training, staff should understand:

• Their obligation to provide meaningful access to information and services to LEP individuals;

• The protocol for handling various encounters with LEP individuals, as established by this plan;

• How to access translated materials and interpretation services for provision to LEP individuals.

Monitoring, Evaluating, and Updating this Plan

As part of their responsibilities, the President of VCC will monitor and evaluate the effectiveness of this plan and make updates accordingly. To do this, (he/she/they) will make use of the following mechanisms:

• Survey staff on how often language assistance services are used and how they could be improved;

• Solicit feedback from community-based organizations and other stakeholders;

• Keep current on community demographics by engaging with local resources.