All fees displayed clearly before account opening or purchase
Why it matters
Reg Z (TILA) requires that all fees be disclosed before a consumer commits to a credit product — and the FTC Click-to-Cancel rule extends a parallel obligation to subscription billing. When a user reaches the confirmation screen without seeing the full cost, they cannot make an informed choice. Post-commitment fee discovery drives chargebacks, erodes trust, and creates regulatory exposure under CFPB enforcement. FINRA Rule 2210 independently prohibits omitting material information in communications with the public, which courts and regulators have applied to investment product fee schedules. Burying fees in linked Terms & Conditions does not satisfy pre-commitment disclosure — the information must appear in the purchase flow itself.
Severity rationale
Critical because a user who commits without knowing the full fee structure cannot give informed consent, exposing the product to CFPB enforcement, FTC action, and chargeback liability simultaneously.
Remediation
Add an explicit fee disclosure section to the pricing page and every checkout confirmation step. In app/pricing/page.tsx (or app/(marketing)/pricing/page.tsx), render every applicable fee with its exact dollar amount before the CTA button:
// app/pricing/page.tsx
<div className="pricing-disclosure">
<h2>All Fees</h2>
<dl className="fee-list">
<div className="fee-row">
<dt>Monthly Service Fee</dt>
<dd>$9.99/mo</dd>
</div>
<div className="fee-row">
<dt>Transaction Fee</dt>
<dd>$0.50 per transfer</dd>
</div>
</dl>
<p className="disclosure-note">
These are the complete fees. No additional or hidden charges apply.
</p>
</div>
Repeat a condensed version in the checkout summary above the "Confirm" button so fee disclosure is never more than one scroll away from commitment.
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 Regulatory Disclosure Audit. The pattern definition, severity rationale, and remediation remain openly licensed under CC-BY-4.0.
External references
- external · reg-z-tila — Regulation Z (TILA) — 12 CFR Part 1026, general disclosure requirements
- external · ftc-click-to-cancel — FTC Negative Option Rule / Click-to-Cancel — pre-purchase fee disclosure
Taxons
History
- 2026-04-18·v1.0.0·Initial import from finserv-disclosure·automated