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#2179214 - 05/22/18 09:04 PM Credit Card "No Annual Fee" A Trigger Term
KeKe Offline
Junior Member
Joined: Sep 2015
Posts: 39
Midwest
I need to confirm that I am understanding correctly that using "No Annual Fee" in marketing a credit card - is a triggering term that requires additional disclosure verbiage as stated in 12 CFR 1026.16 (b)(1).

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#2179465 - 05/23/18 08:19 PM Re: Credit Card "No Annual Fee" A Trigger Term KeKe
BrianC Offline
Power Poster
BrianC
Joined: Nov 2004
Posts: 6,275
Illinois
Correct. The commentary makes this very clear.

"16(b) Advertisement of Terms That Require Additional Disclosures

Paragraph 16(b)(1)

1. Triggering terms. Negative as well as affirmative references trigger the requirement for additional information. For example, if a creditor states no interest or no annual membership fee in an advertisement, additional information must be provided."
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#2212274 - 04/28/19 12:15 AM Re: Credit Card "No Annual Fee" A Trigger Term KeKe
goingtoexperts Offline
100 Club
Joined: Jul 2006
Posts: 149
To confirm this is applicable to all lines of credit - real estate secured, unsecured and those secured by other collateral?

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