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ABA: The American Bankers Association

My bank offers a checking account that entitles holders of the account who open a new home equity line of credit (HELOC) to have the annual fee on the HELOC waived. Because the fee waiver is a key feature of the account, it is clearly noted in the advertisement. Because this is an advertisement for a checking account—not an advertisement for the HELOC—does the advertisement need to include Regulation Z-triggered disclosures?

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