Submission #4

changes requestedReviewed by AI
Product
credit_card
Channel
affiliate_comparison
Filename
affiliate_comparison_0.pdf

5 checks flagged

  • failUDAAP-no-deceptive-representation

    The comparison table gives a misleading net impression that ClearPath has a permanent fixed 0% APR, while later terms state it is only 0% intro for 12 billing cycles and then a variable APR applies.

    “ClearPath Rewards Card 2% all purchases / $0 fee / Fixed 0% APR (permanent)”

  • fail255.5-material-connection-disclosure

    This is a comparison site featuring ClearPath and other cards, which implies potential referral/affiliate relationships, but the material provides no clear disclosure of any compensation or partner connection.

    “Presented by SmartCardCompare.com, an independent card-comparison site.”

  • fail1026.16-actual-terms

    The ad states a specific credit term for ClearPath that conflicts with the actual terms later disclosed, indicating the advertised permanent fixed 0% APR is not actually offered.

    “ClearPath Rewards Card 2% all purchases / $0 fee / Fixed 0% APR (permanent)”

  • fail1026.16-no-misleading-fixed-apr

    The ad refers to the APR as fixed without a compliant fixed-period/no-increase disclosure, and the later terms show the rate is actually introductory for 12 billing cycles before becoming variable.

    “Fixed 0% APR (permanent)”

  • fail1026.16-promo-rate-fee-disclosure

    The advertised 0% APR is actually promotional, but the comparison listing does not label it as introductory or disclose in immediate proximity that it ends after 12 billing cycles and then converts to 18.99%-27.99% variable APR.

    “ClearPath Rewards Card 2% all purchases / $0 fee / Fixed 0% APR (permanent)”