APR/interest rate disclosed prominently on credit pages

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.

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.

• ID: finserv-disclosure.fee-rate.apr-disclosed

• Severity: critical

• What to look for: List all credit, loan, or interest-bearing products in the project. For each, check whether the Annual Percentage Rate (APR), interest rate, or yield rate is displayed prominently on the product detail page, pricing page, or application page. "Prominently" means within the first 500px of page content (above the fold on a standard 1080p display), in a clearly labeled field or section with at least 16px font size equivalent.

• Pass criteria: For every credit or loan product, the APR or interest rate is displayed prominently on the product page with the rate value visible without scrolling past 500px of content. If rates vary, the full range is shown (e.g., "7.00% – 12.00% APR"). Quote the exact APR text and file path where it appears. Report even on pass: "Found APR disclosure for X of Y credit products."

• Fail criteria: No APR/interest rate is disclosed on any product page, or it is only in the terms/conditions document, or it appears below 500px of page content, or the font size renders it in small text relative to surrounding content.

• Do NOT pass when: APR is mentioned only in a linked PDF or Terms & Conditions page — the rate must appear directly on the product page itself.

• Skip (N/A) when: The project offers no credit, loan, or interest-bearing products (e.g., a checking account with no interest, a pure payment service, a savings product with zero yield).

• Detail on fail: Specify which products lack APR disclosure and where it should appear. Quote the file path where the product page lives. Example: "Personal loan product page (app/products/personal-loan/page.tsx) has no APR disclosure. Terms & Conditions document mentions '7-12% APR depending on creditworthiness' but this is not shown on the product page itself."

• Remediation: Users need to know borrowing costs up front. Add APR/rate disclosure to your loan or credit product pages in app/products/personal-loan/page.tsx or equivalent:

  // app/products/personal-loan/page.tsx
  <div className="apr-disclosure">
    <h2>Loan Terms</h2>
    <div className="rate-badge">
      <span className="label">APR Range</span>
      <span className="value">7% - 12%</span>
      <span className="footnote">Based on creditworthiness</span>
    </div>
    <p>
      The annual percentage rate (APR) is the cost of borrowing per year,
      including interest and fees. Your specific APR will be shown at
      application based on your credit profile.
    </p>
  </div>
  

  If rates vary by credit tier or term, show the full range and explain what determines the rate.

• Cross-reference: For TILA-specific APR disclosure requirements on credit applications, see the tila-disclosures check in this same audit.