TILA (Reg Z) disclosures for credit products

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.

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.