APR/interest rate disclosed prominently on credit pages
Why it matters
Reg Z (TILA), codified at 12 CFR 1026.6 and 1026.18, mandates that the Annual Percentage Rate be conspicuously disclosed on credit product pages — not buried in a linked PDF or discoverable only after application. A credit product that hides its APR until post-application exposes users to deceptive lending practices and exposes the company to CFPB enforcement and private right of action under TILA. FINRA Rule 2210 reinforces this for investment credit products: omitting material cost information (such as borrowing rates) from customer-facing communications is a standalone violation. APR buried below the fold on a 1080p display also fails the "prominence" standard regulators apply at examination.
Severity rationale
Critical because APR omission violates Reg Z (TILA) 12 CFR 1026.18 by withholding a mandated material disclosure, creating CFPB enforcement exposure and private TILA claims.
Remediation
Place APR disclosure above the fold on every credit or loan product page. In app/products/personal-loan/page.tsx (or equivalent), render the rate as a visually prominent element before any application CTA:
// app/products/personal-loan/page.tsx
<div className="apr-disclosure" aria-label="Annual Percentage Rate">
<span className="label">APR</span>
<span className="value">7% – 12%</span>
<span className="footnote">
Rate based on creditworthiness. Your exact APR will appear at application.
</span>
</div>
If the product has a single fixed rate, show it directly. If rate ranges apply, display the full range (lowest–highest). Never redirect users to a Terms & Conditions document as the sole APR source.
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-1026-6 — Regulation Z (TILA) — 12 CFR §1026.6, initial disclosure of APR/interest rate
- external · reg-z-tila-1026-18 — Regulation Z (TILA) — 12 CFR §1026.18, content of disclosures for closed-end credit
Taxons
History
- 2026-04-18·v1.0.0·Initial import from finserv-disclosure·automated