Case study № 04
Making a mortgage disclosure actually readable
Regulators require Horizon Bank to show a nine-page disclosure before every mortgage. 94% of applicants clicked through without reading. After redesign, comprehension tests climbed from 22% to 71%.
Measured
Outcomes.
- Comprehension-test pass rate
- 22% → 71%
- Median time on disclosure
- +14 min
- Post-close complaints citing disclosure
- −58%
- Compliance audit findings
- 0
Five multiple-choice questions, 300 applicants
Longer, because applicants are reading
Three quarterly audits since launch
Why this project existed
Mortgage disclosures are the most important document a home buyer sees during origination, and they are also the document buyers are least likely to read. Regulators require the disclosure. Banks produce it to a minimum standard. Applicants click through it to get to the sign button. The disclosure exists, legally, but it does not exist functionally in the buyer’s head.
Horizon Bank had been flagged in two separate CFPB complaints where buyers claimed they had not understood a specific term at origination. The bank’s position in both cases was correct under the law, the disclosure had contained the term, and the buyer had signed. The complaints were dismissed. The bank’s leadership decided, independently of the complaints, that dismissal was not the goal. The goal was that buyers actually understood what they were signing.
The constraint that shaped everything
Unlike a typical content redesign, this one had a hard floor. Certain sentences in the disclosure are mandated verbatim by regulation. We could not paraphrase them. We could not shorten them. We could not reorder them in a way that changed their meaning. The seven-week legal discovery phase was about identifying exactly which sentences had that constraint and which did not.
The output of that phase was a master document with every sentence color-coded. Red sentences were verbatim-mandated. Yellow sentences were content-mandated but wording-flexible. Green sentences were our content entirely. The redesign could only modify yellow and green. Red sentences had to appear, in order, exactly as written.
The three-layer disclosure
The final design uses three stacked layers within each section.
The summary layer, two to three sentences in our plain-language voice, explains what the section means in the buyer’s terms. These are green sentences entirely.
The legal layer contains the full regulator-required text, including the verbatim-mandated red sentences. We set this at the same body size as the summary rather than the tiny type the original used. Buyers can read it without strain.
The glossary layer is anchored, every term that we know tests poorly in comprehension is linked to a definition that opens in a sidebar on desktop or a bottom sheet on mobile. The glossary entry stays open as the buyer scrolls, so they can keep the definition visible while reading the sentence that used the term.
What we cut
An early design had a “plain-language only” mode that hid the legal text. We cut it during the legal review, the legal text has to be present, not optional, per regulation. We kept the summary layer but made the legal text always visible directly beneath it.
An early design also had a comprehension check at the end of each section, a one-question multiple choice before the buyer could proceed. Compliance was enthusiastic about this. Applicants, in testing, found it condescending and were visibly annoyed. We cut it and measured comprehension through a voluntary post-sign survey instead.
Outcomes
Comprehension-test pass rate moved from 22% to 71% across three hundred applicants in controlled testing. Median time on disclosure grew by fourteen minutes, which reads like a bad metric but is precisely the result we wanted, applicants were now actually reading the document.
Post-close complaints citing the disclosure dropped 58% year over year. Three quarterly compliance audits since launch have returned zero findings. Two other banks have asked Horizon to license the framework. Horizon declined, offered to publish the approach as a public case study, and is doing so this year.
What I think about
Content design and product design separate for historical reasons that do not serve the work. On this project there was no line between the two. The words on the page were the product. Every interaction was in service of reading. Calling it “content” or “UX” did not matter.
Approach
Process.
Read the disclosure ten times
Before involving any applicants, the team read the disclosure cover to cover, ten times, in a quiet room. Every paragraph that left anyone confused got flagged. The first pass produced 43 flagged paragraphs out of 112. By the tenth read, we had categorized the confusion, unfamiliar terms, ambiguous references, awkward sentence structure, unclear consequences.
Tested comprehension, not preference
We did not ask applicants if they liked the disclosure. We asked them five multiple-choice questions after reading it. Questions chosen with the compliance team so that a wrong answer mapped to a real regulatory exposure. The baseline was 22% pass rate on the existing disclosure. Any redesign had to clear 60% to be worth shipping.
Designed for the skim, with depth on demand
The redesigned disclosure has three layers. The top layer is a plain-language summary of each section, two to three sentences in body type. Beneath each summary is the legally required text, in the same regulator-mandated language, at body size rather than the 9px fine print of the original. Every term in the legal text that a reader might not know is linked to an anchored glossary that scrolls in a sidebar on desktop and as a bottom sheet on mobile.
Took it through compliance and legal, word by word
The disclosure has regulator-mandated language that cannot be edited, and regulator-required content that can be worded however we choose. Separating the two took seven weeks. We ended up with a spreadsheet of every sentence categorized as 'mandated verbatim', 'mandated meaning', or 'our choice'. The plain-language summaries are ours. The legal text is theirs.
Three regulators have reviewed this disclosure in the past year. Every one of them asked how we built it. We are now the example they point other banks at.
Credits
- Staff Product Designer
- Max Mustermann
- Content Designer
- Tamsin Oyelaran
- Compliance Counsel
- Evan Moretti, JD
- Frontend Engineer
- Siobhan Kerrigan
- Product Manager
- Daichi Tanaka
Toolchain
- Figma
- Hemingway
- Airtable
- Lyssna