Reviewing a brochure which lists the benefits associated with checking accounts, one bullet states "annual fee waived on lines of credit". Since this includes secured and unsecured, full disclosures would be required. Is this accuarate? As always, thanks to the experts!

The commentary to 226.16 (open-end credit: Advertising) states that this would not be a triggering term unless related to a home equity plan:
2. Use of positive terms. An advertisement must state a credit term as a positive number in order to trigger additional disclosures. For example, no annual membership fee would not trigger the additional disclosures required by §226.16(b). (See, however, the rules in §226.16(d) relating to advertisements for home equity plans.)

I have read the commentary in 226.16 and understand it is a triggering term only for home equities. However, this offer would apply to both secured and unsecured lines of credit. What are the requirements when it applies to both type of products?

The true test would be not what the offer applies to but which offer you advertise. Since your advertisement covers both unsecured and HELOCs, the triggering situation would "trump" the non-triggering one and disclosures would be required.

You could include a blurb in the disclosure section "For home equity lines..." or "secured lines of credit..." if you wish.

Thanks. I just wanted to ensure a brochure or presentation material which lists the benefits of a particular checking account is considered an advertisement and the benefit of "annual fee waived" requires full disclosures. Have a nice day!