Title VI of the Civil Rights Act of 1964

In accordance with Title VI of the Civil Rights Act of 1964, The Community Impact Fund, as a recipient of Federal funding, will not discriminate against any person based on age, color, creed, disability, familial status, national origin, race, religion, sex or on any other basis legally prohibited by or protected by Federal or State law. The Community Impact Fund will not exclude anyone from participation in programs and services, or deny persons the benefits thereof, or subject anyone to discrimination on the grounds of race, color, national origin, sex, age, or disability. Questions, concerns, comments or requests for accommodation, whether from employees or clients, should be made to The Community Impact Fund’s Title VI/Section 504 (ADA) Coordinator, Courtney Lussenhop, VP of Impact, info@communityimpactfund.org, 303-800-8289, who is designated by the President/CEO. 

 

The Community Impact Fund will comply with Title VI of the Civil Rights Act of 1964 and all requirements imposed therein and will immediately take any measures necessary to effectuate this policy. The Community Impact Fund will compile data, maintain records and submit reports as required to permit effective enforcement of Title VI, and permit authorized funding agency personnel during normal working hours to review and copy such records, books and accounts as needed to ascertain compliance with Title VI.  

 

Section 504 (Americans with Disabilities Act)

Pursuant to Section 504 of the Rehabilitation Act of 1973 (Section 504), the Americans with Disabilities Act of 1990 (ADA) and related federal and state laws and regulations, The Community Impact Fund will make every effort to ensure that its facilities, programs, services, and activities are accessible to those with disabilities. The Community Impact Fund will provide reasonable accommodation to persons with disabilities who wish to participate in public involvement events or who require special assistance to access The Community Impact Fund facilities, programs, services or activities. Questions, concerns, comments or requests for accommodation (whether by employees or clients) should be made to The Community Impact Fund’s Title VI/Section 504 (ADA) Coordinator, Courtney Lussenhop, VP of Impact, info@communityimpactfund.org, 303-800-8289, who is designated as such by the President/CEO.

 

Section 504 protects individuals with disabilities, including those who:

1. Have a physical or mental impairment that substantially limits one or more major life activities.

• Physical impairments include limited vision or hearing, limited mobility (including people who use wheelchairs, canes, or walkers), infectious diseases (including AIDS) and others.
• Mental impairments include mental retardation, organic brain syndrome, emotional or mental illness and specific learning disabilities.
• Major life activities are everyday things such as walking, talking, seeing, hearing, working or caring for oneself.

OR

 

1. Have a record of an impairment, such as a history of a disability or misclassification as having a disability.

OR

 

1. Are regarded as having an impairment.  (Someone treats the person as if he/she has an impairment whether or not the person actually does.)

 

The Community Impact Fund will ensure persons with disabilities who are eligible for programs and services are able to participate in and benefit from programs receiving federal financial assistance as much as people without disabilities. To that end, persons with disabilities should be able to enter and use The Community Impact Fund facilities (or those rented/leased by The Community Impact Fund) for delivery of programs and services. The Community Impact Fund will provide the most integrated settings possible, in which persons with disabilities are not separated from non-disabled people, unless there is no other reasonable choice; or special services must be provided to enable the people with disabilities to participate.

The Community Impact Fund will provide reasonable accommodation, which includes any modification or adjustment to programs and services, or program/service delivery environments, that will enable an applicant or participant to participate in The Community Impact Fund’s programs and services. Reasonable accommodation also includes adjustments to assure that an individual with a disability has rights and privileges in employment equal to those of employees without disabilities.

Any action that denies a qualified individual with equal treatment or equal opportunity to benefit from programs or activities is considered discriminatory.

 

1. The Community Impact Fund uses Telecommunications Relay Service (TRS),  which relays calls between deaf, hard of hearing or speech impaired individuals who use a TTY, Captel or VCO to communicate on the telephone. Video Relay Services (VRS) are also available, allowing consumers using American Sign Language to communicate in their native language through video interpreters. TRS numbers are communicated to the public as part of The Community Impact Fund’s standard outreach, marketing and client intake documents.
2. Conduct a self-evaluation of policies, practices and facilities.  The Community Impact Fund operates fully remotely.  Any problems with programs, policies and procedures have been or are being addressed and resolved. The self-evaluation is periodically updated and, if needed, a Section 504 transition plan is established to make changes found necessary during the self-evaluation. Modifications, if necessary, must be made within four years.

 

Grievance Procedure for Complaints Relating to Allegations of Suspected Discrimination

Any person, employee or citizen who believes that he/she has been subjected to discrimination may personally or by a representative file a complaint with The Community Impact Fund’s Title VI/Section 504 (ADA) coordinator, Courtney Lussenhop, VP of Impact,info@communityimpactfund.org, 303-800-8289.  A person who has not personally been subjected to discrimination may also file a complaint.

Step One: An aggrieved person must submit a written statement to the Title VI/Section 504 (ADA) coordinator setting forth the nature of the discrimination alleged and facts upon which the allegation is based.

Step Two: The Title VI/Section 504 (ADA) coordinator shall contact the complainant no later than fifteen (15) days after receiving the written statement to establish an informal meeting with the objective of resolving the matter informally.  However, in no case shall the informal meeting be conducted sooner than five (5) days or more than forty-five (45) days after receiving the written statement. There shall be prepared a written documentary of the discussions at the informal meeting, which shall be preserved in The Community Impact Fund’s records.

Step Three: Within fifteen (15) days of the informal meeting, if no decision has been made by Title VI/Section 504 (ADA) coordinator or the decision of the Title VI/Section 504 (ADA) coordinator does not satisfy the complainant, complainant may request a hearing with the The Community Impact Fund President/CEO by submitting a written request to the Title VI/Section 504 (ADA) coordinator or directly to the President/CEO.

Step Four: In discussing the grievance, the complainant may designate any person of his/her/their choice to appear with him/her/them and participate in the discussion.  The Community Impact Fund  shall issue a written decision on the matter within fifteen (15) days, and the decision shall be the final procedure for the complainant at the local level.

Step Five: Complainant may appeal the decision of the President/CEO and/or Title VI/Section 504 (ADA) coordinator to The Community Impact Fund’s Board of Directors. The Board shall hear the complaint and issue a written decision within 15 fifteen (15) days of the complaint.

Step Six: Complainant may also file a complaint with:

Colorado Civil Rights Division

https://ccrd.colorado.gov/ccrd-home/regulatory-information/colorado-civil-rights-commission

1560 Broadway, Suite 825

Denver, CO 80202

Phone: 303-894-2997 (para español, oprima dos) |  711 TTD – Relay

Fax: 303-894-7830  

General Inquiries: DORA_CCRD@State.co.us

Intake Unit: DORA_CCRDIntake@State.co.us 

ADR Unit (Mediation and Conciliation): DORA_CCRDADR@State.co.us

Investigations Unit: DORA_CCRDInvestigations@State.co.us 

 

Or:

U.S. Department of the Treasury, 

Director, Office of Civil Rights and Equal Employment Opportunity 

1500 Pennsylvania Avenue, N.W., 

Washington, DC 20220

Or, send an e-mail to: crcomplaints@treasury.gov.

The Community Impact Fund

Limited English Proficiency Assessment 

and Language Access Plan

 

LEP Assessment

FOUR-FACTOR LEP ANALYSIS:

As a recipient of federal funding, The Community Impact Fund (CIF) is required to conduct an LEP assessment that considers the following four factors to determine whether a Language Access Plan (LAP) is required and what elements should be included.

 

Factor #1: The number or proportion of LEP persons served or encountered in the eligible service population (“served or encountered” includes those persons who would be served or encountered by CIF if the persons received adequate education and outreach and CIF provides sufficient language services).

 

CIF’s mission is to partner with employers to empower Asset Limited, Income Constrained, Employed (ALICE) individuals towards financial security.

 

CIF offers 0% interest-free charitable loans (Impact Loans). Loan repayment takes place over a 12-month schedule and is set up to be automatically debited from the borrower’s bank account on the day of their choosing. This loan helps to bridge cash flow and pay emergency expenses without accruing extra fees or increasing high-interest debt.

 

This gives us an opportunity to meet the very real needs in our communities while also restoring dignity back to those receiving the funds. This is the key to prospering communities worldwide.

This fully automated, tech-enabled process was built around respecting the dignity of the applicant. 

 

CIF is an emerging Community Development Financial Institution, planning to seek certification through the U.S. Department of Treasury, CDFI Fund in the near future. Its financial product is offered nationally.

 

CIF provides services nationally. Its Limited English Proficiency profile, based on 2023 American Community Survey S1602 (5-Year Estimates) data, reflects:

• 78% of the nation’s population speaks only English.
• 22% speak a language other than English.
• 26,299,012 persons, or 8.4% of the population, speak English “less than very well”. Of persons speaking English “less than very well”, 37% speak Spanish, 31% speak other Indo-European Languages, 44.1% speak Asian and Pacific Island Languages, and 29.6% speak other languages.

 

Because more than 1,000 LEP persons are in SKED’s service area, SKED will provide appropriate language assistance by: 

 

1. Offering translation of all vital documents; 
2. Posting notices of public hearings and similar public comment events on its website for LEP persons of the threshold population(s) in the language(s) spoken; and 
3. Providing translation services at public hearings, if requested to do so by LEP persons.

 

Factor #2: The frequency with which LEP persons come into contact with the program.

LEP persons come into contact with CIF’s programs in proportion to their presence in the overall population.

 

Factor #3: The nature and importance of the program, activity, or service provided by the program.

CIF provides 0% interest loans to persons unable to access capital readily through traditional financial institutions. It provides development services, which include financial literacy through monthly newsletters, quarterly webinars, and a curated financial literacy resource portal in tandem with its lending activities.

Factor #4: The resources available and costs to the recipient.

CIF accesses private sector translation services as needed to ensure LEP persons have access to translated vital documents.

 

Based on the four-factor analysis above, CIF is required to have a Language Assistance Plan.

The Community Impact Fund Language Access Plan

CIF offers 0% interest-free charitable loans (Impact Loans). Loan repayment takes place over a 12-month schedule and is set up to be automatically debited from the borrower’s bank account on the day of their choosing. This loan helps to bridge cash flow and pay emergency expenses without accruing extra fees or increasing high-interest debt.

 

This gives us an opportunity to meet the very real needs in our communities while also restoring dignity back to those receiving the funds. This is the key to prospering communities worldwide.

This fully automated, tech-enabled process was built around respecting the dignity of the applicant. 

 

CIF is an emerging Community Development Financial Institution, planning to seek certification through the U.S. Department of Treasury, CDFI Fund in the near future. Its financial product is offered nationally.

 

CIF provides services nationally. Its Limited English Proficiency profile, based on 2023 American Community Survey S1602 (5-Year Estimates) data, reflects:

• 78% of the nation’s population speaks only English.
• 22% speak a language other than English.
• 26,299,012 persons, or 8.4% of the population, speak English “less than very well”. Of persons speaking English “less than very well”, 37% speak Spanish, 31% speak other Indo-European Languages, 44.1% speak Asian and Pacific Island Languages, and 29.6% speak other languages.

 

CIF takes the following proactive measures to ensure meaningful access for LEP persons:

1. Staff have the USDA  “I Speak” card and can provide it to employers to assist employees who may desire to access CIF’s programs, to identify the primary language of the LEP person.
2. One hundred percent of CIF staff work remotely. When interacting remotely with potential clients, staff will provide clients with a link to required notices housed on CIF’s website in 1) the most predominant non-English language (Spanish), or 2) The client’s primary language, describing the Federal laws prohibiting job discrimination based on race, color, sex (including pregnancy and related conditions, sexual orientation, or gender identity), national origin, religion, age (40 and older), equal pay, disability or genetic information (including family medical history or genetic tests or services), and retaliation for filing a charge, reasonably opposing discrimination, or participating in a discrimination lawsuit, investigation, or proceeding. 
3. For all LEP populations identified above, CIF has Equal Opportunity brochures and non-discrimination posters available in the applicable languages, available at https://www.eeoc.gov/poster
4. As a national service provider, CIF maintains an internal list of statewide/regional private translation service agencies, and agencies that provide services nationally. As needed, it will engage private sector commercial translation services to provide clients with translated vital documents.
   

 

The table above is the S1601 table accessible through census.gov. 

HUD Safe Harbor Provisions