APR disclosure: welding the terms to the number

Truth in Lending Act / Regulation Z — 12 CFR 1026, incl. §1026.24 (advertising) and the clear-and-conspicuous standard

• If you state a rate, state it as an “annual percentage rate,” using that term.
• If the APR can increase after consummation, say so.
• When an advertised rate triggers additional disclosures, present them with equal prominence and in close proximity to that rate.
• Make required disclosures clear and conspicuous — not obscured by shading, coloring, graphics, or interactions that hide them.

Reg Z sets a prominence and proximity bar. It does not tell you to use a modal, a tooltip, an accordion, or a particular layout — only that whatever you choose can’t bury the terms.

• “APR” has to be a component, not a label — the number and its qualifying terms render as one unit that responsive breakpoints can’t split.
• A tooltip or a “see details” link generally fails “close proximity and equal prominence” for the triggered disclosures — the terms need to be visible where the rate is.
• Marketing surfaces and product surfaces should share one disclosure component so an A/B test can’t quietly drop it.
• If the rate is a range or “rates from X%”, the representative example and its assumptions ride along with it.

• A rate unit: APR value + the term “annual percentage rate” + variable-rate statement + fee summary
• A representative-example block for ranges and “rates from”
• A full-terms surface (screen or expandable panel) that’s reachable but not a substitute for the inline terms
• Consistent placement across ad, landing page, in-flow, and confirmation

TILA carries statutory damages and a private right of action, is a standard exam focus, and advertising violations have produced CFPB enforcement actions.

• eCFR — 12 CFR 1026.24 (Advertising)
• CFPB — Regulation Z § 1026.24 and Official Interpretations

Last reviewed 2026-08-28. Verify against the primary source before you ship.