HUD HCV Guidebook § 4.1

Persons who have limited ability to read, write, speak, or understand English can be considered LEP
individuals and may be entitled to language assistance with respect to a particular type of service, benefit, or
encounter. Persons who have difficulty communicating with a PHA generally identify themselves as being LEP
individuals. There is no one way to determine if a person is limited English proficient. Some persons can be
English proficient in some contexts and limited in others. For example, a person may identify as LEP if there
are legal issues involved with technical language but can feel comfortable doing an annual reexamination
without language assistance.

For a PHA, LEP persons include not only LEP applicants for housing assistance and current participants but
also could include anyone inquiring or communicating on behalf of applicants or participants, such as parents

120 See 24 CFR 8.53(b).
121 Grievance procedures do not need to be established with respect to complaints from applicants for employment or from applicants

for admission to housing.
122 See Final Guidance to Federal Financial Assistance Recipients Regarding Title VI Prohibition Against National Origin Discrimination

Affecting Limited English Proficient Person, 72 Fed. Reg. 2731 (Jan. 22, 2007) (hereinafter Final LEP Guidance), available at
https://www.hud.gov/sites/documents/FINALLEP2007.PDF.
123 See Office of General Counsel Guidance on Fair Housing Act Protections for Persons with Limited English Proficiency, (Sept. 15,

2016), (hereinafter Fair Housing Act LEP Guidance), available at https://www.hud.gov/sites/documents/LEPMEMO091516.PDF.
124 See Final LEP Guidance.

Fair Housing and Nondiscrimination Requirements                                                                            32
US Department of Housing and Urban Development                                                                     April 2025

of LEP or English-proficient minors and dependents, and family members who encounter the PHA. It could
also include anyone inquiring with regard to the services provided by the PHA.