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New module: Disclosure.fs (FCA CONC, EU SECCI, US TILA) #49

Description

@simontreanor

Add a new Disclosure.fs module to compute the key regulatory metrics required for consumer credit documentation across UK and international regimes.

1. FCA MCOB / CONC rule calculations (UK mortgages and consumer credit)

Key figures: APR, TCC, Total Amount Payable, representative APR — all consistent with FCA-mandated methodology.

2. EU Consumer Credit Directive — SECCI (Standard European Consumer Credit Information)

Standardised pre-contractual information sheet. Key figures: APR (using the EU CCD formula, which differs slightly from the UK CCA method post-Brexit), TCC, repayment schedule.

3. TILA (US Truth in Lending Act) disclosures

  • Finance charge: Total cost of credit in dollar terms.
  • Amount financed: Principal minus any prepaid finance charges.
  • APR: TILA-specific calculation (differs from UK/EU methodology).

Design principle: Each disclosure function should accept a fully-populated AmortisationSchedule as its primary input so that all disclosure figures remain consistent with the amortisation model rather than being computed independently.

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