Credit Card "No Annual Fee" A Trigger Term

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).

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."

To confirm this is applicable to all lines of credit - real estate secured, unsecured and those secured by other collateral?