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3 INTRODUCTION Many individuals living in San Leandro for whom English is not their primary language may speak English with limited proficiency or, in some cases, not at all. As a result, persons who are Limited English Proficient (LEP) may not have the same access to important housing and social services as those who are proficient in English. LEP residents may also lack the social networks to connect them to programs and social services. Or, if connected to the programs, LEP residents may not understand the details of programs that could qualify them for other services due to linguistic barriers. For these and other reasons, LEP individuals may encounter considerable barriers to programs and social services. To ensure that as many LEP residents as possible receive equal access to all programs and services, the City must comply with the following regulatory requirements:  Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of race, color, and national origin in programs and activities receiving federal financial assistance. When federal funds are passed through a recipient to a subrecipient, subrecipients must also comply with Title VI regulations.  Executive Order 13166 (EO 13166), entitled “Improving Access to Services by Persons with Limited English Proficiency”, directs all federal agencies to work to ensure that programs receiving federal financial assistance provide meaningful access to LEP persons. The Executive Order also requires that federal agencies work to ensure that recipients of federal financial assistance provide meaningful access to their LEP applicants and beneficiaries.  HUD’s regulation, 24 CFR Part 1, ‘‘Nondiscrimination in Federally Assisted Programs of the Department of Housing and Urban Development— Effectuation of Title VI of the Civil Rights Act of 1964,’’ requires all recipients of federal financial assistance from HUD to provide meaningful access to LEP persons.  HUD’s “Final Guidance to Federal Financial Assistance Recipients Regarding Title VI Prohibition Against National Origin Discrimination Affecting Limited English Proficient Persons”, 1/22/07, requires that federally assisted recipients: o Conduct a “four-factor analysis”; o Develop a language access plan (LAP) if necessary; and, o Provide appropriate language assistance. FOUR-FACTOR ANALYSIS This section uses HUD’s four-factor analysis to determine the eligible LEP population(s) and the level of language services to be provided to LEP individuals by the City. The four-factor analysis is intended to impart flexibility for implementing a program that meets the intent of federal guidelines for a LAP without imposing undue burdens on recipients’ or subrecipients’ financial resources or organizational capacity.