An assignment of beneficial interest (ABI) in a land trust might not be considered a designated loan. Under the Illinois Land Trust Recordation and Transfer Tax Act and Land Trust Beneficial Interest Disclosure Act, the beneficiary’s interest in a land trust is defined as “personal property only.” 765 ILCS 405/1765 ILCS 420/2. Further, the Interagency Questions and Answers Regarding Flood Insurance state that where a lender takes a note as collateral on a loan, rather than securing the loan directly by the real estate, the loan is not a designated loan subject to the flood insurance requirements. Question 42, 74 Fed. Reg. 35914, 35941 (July 21, 2009). By analogy, where a lender takes a personal property interest in a land trust as collateral rather than securing the loan directly by the real estate, the loan might not be considered a designated loan.