Our adjustable rate HELOCs have a feature that allows the customer to lock in a portion of the existing balance at a fixed rate. Would a HELOC advertisement that mentions this fixed rate option trigger the additional disclosures under Reg Z? Thanks.

Are you advertising a particular rate or APR? If so, look at the trigger terms for Open-end credit. Your product does not have an introductory rate (which tiggers additional disclosures) If you are simply making a general statement and do not include trigger terms - it doesn't appear that you need additional disclosures.

The advertisement doesn't have anything else that would be a triggering term, so it would come down to the reference to a fixed rate option.

We showed an earlier version that included the rate information to our examiner. At that point all the triggered information was already there so we didn't address whether the reference to a fixed rate option would be a triggering term. But our examiner did say that we should provide some detail about what the fixed rate feature is and how it works. His recommendation was based on the ad being potentially misleading/deceptive.