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6 eligible population and more than 50 in number), the City will translate vital documents and written notices for this group. It will have to be determined which A/PI, Indo European, and other populations, if any, meet the HUD criteria for translated documents. Because the City recognizes the ethnic diversity in the community, the City already translates certain “vital” housing-related documents into Spanish and Chinese. Factor 2. The frequency with which LEP persons come into contact with the program. The City is a direct provider of services as well as an indirect provider through our role as a funder of community-based organizations (CBOs) that offer services inside and outside the City. The City refers many clients seeking housing services to third-party CBOs who are more likely to fulfill their needs better. However, neither the City, nor our subrecipients, collect data on LEP persons who seek our housing services. However, the City employs 47 staff members citywide who have qualifying translation skills to provide language assistance to a LEP person. Two City staff members are also qualified to provide ASL services. In reviewing the number of instances various languages were used citywide for FY2009-10, Spanish and Mandarin were the predominant languages provided to residents. The breakdown is as follows: LANGUAGES/ASL PROVIDED CITYWIDE IN FY09-10 NUMBER OF TIMES LANGUAGE ASSISTANCE PROVIDED IN FY09-10 PERCENTAGE OF LANGUAGE ASSISTANCE PROVIDED TO ETHNICITIES Spanish 598 87% Mandarin 51 7% Cantonese 14 2% Hindi 9 1% Tagalog 8 1% ASL (American Sign Language) 14 2% TOTAL 694 100% Of the 694 instances where language accessibility was provided in FY09-10, the City assisted with 598 (or 87%) of Spanish language assistance and 51 (or 7%) of Mandarin language assistance. Spanish and Mandarin were the predominant languages provided to residents by City staff. Anecdotal evidence from conversations with program staff within the City also suggests that Spanish and Mandarin speakers have the most contact with City services. Factor 3: The nature and importance of the program, activity, or service provided by the program. City staff responded to 173 phone inquiries and walk-in visitors in FY09/10. Fifty-eight (58) seniors also received additional information relevant to their special needs. Once the LAP is fully implemented, the City will be better equipped to assess the importance of the programs for LEP persons. Currently, most of the programs require some working knowledge of English to participate in them due in part to legal documents that are required.