Equal opportunity notice (Reg B) on credit applications

Regulation B (Equal Credit Opportunity Act), 12 CFR 1002.9, requires creditors to notify applicants of their rights under ECOA at the point of application. Placing this notice only in a Terms & Conditions document does not satisfy Reg B — the notice must appear on or immediately adjacent to the application form itself. A missing or inadequate equal opportunity notice exposes the company to both CFPB enforcement and private ECOA claims, and courts have not been sympathetic to the argument that a hyperlinked document satisfies the co-location requirement. The notice must enumerate protected characteristics; a generic nondiscrimination statement that omits the statutory list of characteristics is insufficient.

Add the ECOA notice inline on every credit application form page, not in linked documents. In app/apply/credit-card/page.tsx (or equivalent), render the notice inside the form before the submit button:

// app/apply/credit-card/page.tsx
<div className="equal-opportunity-notice">
  <h3>Equal Credit Opportunity</h3>
  <p>
    The Federal Equal Credit Opportunity Act prohibits creditors from
    discriminating against credit applicants on the basis of race, color,
    religion, national origin, sex, marital status, age, or because all or part
    of an applicant&apos;s income derives from any public assistance program. If
    you believe you have been discriminated against, contact the Federal Trade
    Commission at consumer.ftc.gov.
  </p>
</div>

Verify the notice names at least four protected characteristics. Reproduce it on every distinct credit application page — a single Terms page does not satisfy the co-location requirement.

• ID: finserv-disclosure.terms-legal.equal-opportunity-notice

• Severity: high

• What to look for: List all credit application pages in the project (loan applications, credit card applications, line of credit forms). For each, check whether a Regulation B (Equal Credit Opportunity Act) notice is displayed on the same page as the application form. The notice must mention at least 4 protected characteristics (race, color, religion, national origin, sex, marital status, age, public assistance).

• Pass criteria: A Reg B notice is displayed on or immediately adjacent to every credit application form (within the same page, not in a linked document). The notice explicitly names at least 4 protected characteristics. Quote the text of the notice found and the file path where it appears.

• Fail criteria: No equal opportunity notice appears on the credit application page, or the notice is only in the terms document, or the notice names fewer than 4 protected characteristics.

• Skip (N/A) when: The project does not offer credit, loans, or credit applications.

• Detail on fail: Quote the application page file path. Example: "Credit card application form at app/apply/credit-card/page.tsx lacks the required Equal Credit Opportunity Act notice. Only the Terms & Conditions document mentions nondiscrimination."

• Remediation: Add a Reg B notice to your credit application page in app/apply/credit-card/page.tsx or equivalent:

  // app/apply/credit-card/page.tsx
  <form className="credit-app">
    <h1>Credit Card Application</h1>
  
    <div className="equal-opportunity-notice">
      <h3>Equal Credit Opportunity</h3>
      <p>
        The Federal Equal Credit Opportunity Act prohibits creditors from
        discriminating against credit applicants on the basis of race, color,
        religion, national origin, sex, marital status, age, or because all or
        part of an applicant's income derives from any public assistance program.
        If you believe you have been discriminated against, contact the Federal
        Trade Commission at consumer.ftc.gov or your state's attorney general.
      </p>
    </div>
  
    {/* Application form fields */}
  </form>