Disclosures updated after regulatory changes

CFPB supervision includes examination of whether regulated entities monitor and respond to regulatory changes that affect consumer disclosures. A financial product whose Privacy Policy or Terms of Service has no version number and no last-updated date cannot demonstrate regulatory currency — examiners will treat undated documents as potentially stale. The CCPA was amended by CPRA in 2023; TILA has seen Reg Z updates in 2024; FTC Click-to-Cancel rules took effect in 2024. A product operating without dated, versioned legal documents that reflect these changes is operating on borrowed time. The business risk is not just regulatory: users who discover they agreed to a Terms document from three years ago that no longer reflects actual practices have grounds for misrepresentation claims.

Add version metadata and a change summary to every legal document. In app/privacy/page.tsx (and equivalently in terms, fee schedule pages):

// app/privacy/page.tsx
<header className="document-header">
  <h1>Privacy Policy</h1>
  <dl className="document-meta">
    <dt>Version</dt><dd>2.3</dd>
    <dt>Last Updated</dt><dd>February 15, 2024</dd>
    <dt>Next Review</dt><dd>February 15, 2025</dd>
  </dl>
  <details>
    <summary>Change History</summary>
    <ul>
      <li>v2.3 (Feb 2024): Added CFPB data sharing disclosure per updated Reg rules</li>
      <li>v2.2 (Aug 2023): Updated data retention schedule per CCPA/CPRA</li>
    </ul>
  </details>
</header>

Set a calendar reminder for an annual review cycle. Regulators expect documents dated within 18 months to reflect current law.