"Fees for ATM or electronic transfer services (such as preauthorized transfers or home banking services) not required to obtain an account" are specifically excluded from the regulation's description of maintenance and activity fees that would prevent the use of the word "free" to describe the account (see the Commentary).
As long as the card is not required to obtain or maintain the account, you need not consider the fee for the card as defeating your ability to use "free" to describe the account in advertising.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8