Service availability and supported regions listed
Why it matters
State money transmitter laws impose geographic licensing requirements that vary by jurisdiction — offering a payment or lending product in a state without the required license is a strict-liability violation. A product that does not disclose its supported regions forces users from unlicensed states to apply, have their application rejected, and potentially have their personal data collected without regulatory authority. Beyond licensing, geographic availability disclosure is required under CFPB fair lending principles: if a product is not available in certain regions, that limitation must be transparent to prevent disparate impact claims. A user who discovers post-application that their state is not supported has a legitimate data minimization complaint under CCPA and GDPR.
Severity rationale
Info because the disclosure gap is a transparency deficiency rather than an active harm, but operating in unlicensed states without geographic availability disclosures creates strict liability under state money transmitter laws.
Remediation
Add a geographic availability statement to every product page and to the site footer. In app/products/savings-account/page.tsx:
// app/products/savings-account/page.tsx
<aside className="availability-notice">
<h2>Where We Operate</h2>
<p>
Available in all 50 US states and Washington DC. Not yet available outside
the United States. If your state is listed as unsupported during signup,
we are actively working on licensing — join the waitlist to be notified.
</p>
<p>
Customer support: Monday–Friday, 9 AM–9 PM ET. Online access is 24/7.
</p>
</aside>
For products with state-by-state licensing gaps, list unsupported states explicitly rather than requiring users to discover the limitation at application. Add availability information to the FAQ at app/help/faq/page.tsx as well, since users frequently search FAQ before applying.
DetectionPro
The detection method for this pattern is part of AuditBuffet Pro.
The full method (what to look for, pass and fail conditions, and how results get reported) ships inside the Regulatory Disclosure Audit. The pattern definition, severity rationale, and remediation remain openly licensed under CC-BY-4.0.
External references
- external · state-money-transmitter-laws — State money transmitter licensing laws — geographic availability and licensing disclosures required by state
Taxons
History
- 2026-04-18·v1.0.0·Initial import from finserv-disclosure·automated