Financial services compliance — licensing disclosures, risk disclosures, APR caps
Why it matters
US Truth in Lending Act (TILA), FINRA disclosure rules, and both Apple guideline 3.1.5 and Google Play's Financial Services policy require specific, verifiable disclosures before a user commits to a financial product — investment risk warnings, APR disclosure on loans, and broker-dealer registration confirmations. Missing these is not a gray area: FINRA and the CFPB actively pursue enforcement against app developers, and civil penalties start in the tens of thousands per violation. An investment app missing 'past performance does not guarantee future results' or a lending app missing APR disclosure can be rejected, removed, and fined independently.
Severity rationale
High because financial regulation violations create legal liability with civil penalties that exist independently of the app store enforcement action, and regulators can pursue the developer directly without involving Apple or Google.
Remediation
Add required disclosures to every screen where a financial decision is made — not buried in a ToS screen, but visible at the point of commitment:
// src/screens/Portfolio.tsx
<RiskDisclosure>
Investing involves risk. Past performance does not guarantee future results.
You may lose some or all of your invested capital.
</RiskDisclosure>
For lending flows, display APR before the user taps the final confirmation:
// src/screens/LoanApplication.tsx
<Text>Annual Percentage Rate (APR): {formatAPR(loan.apr)}%</Text>
<Text>Total cost of credit: {formatCurrency(loan.totalCost)}</Text>
Remove any lending product with APR >36% or repayment period <60 days — these are prohibited by both stores, not just regulated. Consult a financial regulatory attorney before submitting any investment, brokerage, or insurance app.
DetectionPro
The detection method for this pattern is part of AuditBuffet Pro.
The full method (what to look for, pass and fail conditions, and how results get reported) ships inside the App Store Policy & Content Compliance Audit. The pattern definition, severity rationale, and remediation remain openly licensed under CC-BY-4.0.
External references
- external · us-tila — US Truth in Lending Act (Regulation Z) — APR Disclosure Requirements
- external · apple-guideline-3.1.5 — App Store Review Guidelines 3.1.5 — Real-Money Gaming and Lotteries
- external · google-play-financial-services — Google Play Developer Policy — Financial Services
- external · finra-disclosure — FINRA Rule 2210 — Communications with the Public (disclosure requirements)
Taxons
History
- 2026-04-18·v1.0.0·Initial import from app-store-policy-compliance·automated