Reg Z (TILA), 12 CFR 1026.18, requires creditors to disclose six specific fields — APR, finance charge, amount financed, total of payments, payment schedule, and prepayment penalty — before consummation of a credit transaction. Omitting any of these fields is not a technicality; CFPB examiners treat each missing field as a separate violation. A product that surfaces only the APR while omitting the finance charge and total of payments deprives users of the information they need to compare loan costs across lenders. The CFPB's TILA guidance (cfpb-tila-guide) specifies that disclosures must be "clear and conspicuous" and delivered in writing before the consumer is bound.
High because TILA 12 CFR 1026.18 treats each missing field as a discrete disclosure violation, with CFPB enforcement authority including civil money penalties and restitution orders.
Create a dedicated TILA disclosure section reachable within one click from the loan product page. In app/disclosure/tila/page.tsx, render all six required fields as a structured table:
// app/disclosure/tila/page.tsx
<section className="tila-disclosure">
<h2>Federal Truth-in-Lending Disclosure</h2>
<table>
<tbody>
<tr><td>Annual Percentage Rate (APR)</td><td>8.5%</td></tr>
<tr><td>Finance Charge</td><td>$4,276</td></tr>
<tr><td>Amount Financed</td><td>$10,000</td></tr>
<tr><td>Total of Payments</td><td>$14,276</td></tr>
</tbody>
</table>
<p><strong>Payment Schedule:</strong> 60 monthly payments of $237.93</p>
<p><strong>Prepayment Penalty:</strong> None.</p>
</section>
Link this page directly from the "Apply Now" button on every loan product page. Do not embed TILA disclosures only inside a Terms & Conditions document.
ID: finserv-disclosure.fee-rate.tila-disclosures
Severity: high
What to look for: If the project offers credit or loans (personal loans, credit lines, mortgages, auto loans), enumerate all 6 required TILA disclosure fields: (1) APR, (2) finance charge, (3) amount financed, (4) total of payments, (5) payment schedule, and (6) prepayment penalty statement. Count how many of the 6 are present on a dedicated disclosure page or section.
Pass criteria: For credit products, a disclosure page or section exists that includes at least 5 of the 6 required TILA fields: APR, finance charge amount, amount financed, total of payments, payment schedule, and prepayment penalty statement. The disclosure page must be reachable within 1 click from the loan product page. Quote the file path where the TILA disclosure lives. Report the count: "X of 6 required TILA fields present."
Fail criteria: Fewer than 5 of the 6 required TILA fields are present, or disclosures exist only in the terms document without a dedicated disclosure page/section reachable within 1 click.
Skip (N/A) when: The project offers no credit, loans, or other products subject to Regulation Z.
Detail on fail: List which of the 6 required TILA disclosures are missing. Example: "Loan application page (app/products/personal-loan/page.tsx) shows APR and finance charge but lacks payment schedule, amount financed breakdown, and prepayment penalty disclosure. 2 of 6 required TILA fields present."
Remediation: Create a standardized TILA disclosure for each credit product in app/disclosure/tila/page.tsx or as a section on the product page:
// app/disclosure/tila/page.tsx
<section className="tila-disclosure">
<h2>Loan Estimate & Disclosure</h2>
<table>
<tr>
<td>Loan Amount (Principal)</td>
<td>$10,000</td>
</tr>
<tr>
<td>Annual Percentage Rate (APR)</td>
<td>8.5%</td>
</tr>
<tr>
<td>Finance Charge</td>
<td>$4,276</td>
</tr>
<tr>
<td>Amount Financed</td>
<td>$10,000</td>
</tr>
<tr>
<td>Total of Payments</td>
<td>$14,276</td>
</tr>
</table>
<p>
<strong>Payment Schedule:</strong> 60 monthly payments of $237.93<br />
<strong>Prepayment Penalty:</strong> None. You may pay off this loan
early without penalty.
</p>
</section>
Cross-reference: For broader consumer protection compliance beyond TILA, the FTC Consumer Protection audit covers deceptive practices, endorsement disclosures, and subscription dark patterns.