When the checkout button becomes a credit product, the app inherits a lender's duties — and the CFPB's 2024 interpretive rule settled the question of which ones.
Digital accessibility litigation found the financial app years ago, and the industry's working standard — WCAG 2.1 AA — is now the diligence line bank partners read.
The operating systems rebuilt their permission models around least disclosure — and fintech apps inherit both the protections and the compliance expectations that follow.
The regulator's question about a fintech app is no longer what the disclosure says — it is what the design made the consumer do with it.
A banking app answers to two rulebooks before it ever reaches a customer — the financial regulators' and the platform reviewers' — and neither defers to the other.