We are not aware of any term limits under Illinois law, but the answer may depend on the individual public agency’s investment policy. As we have discussed, there are no Illinois rules or regulations adopted at the state level that are directly on point regarding the investment policies and collateral requirements of local government units. Instead, all public agencies must adopt written investment policies, including “guidelines regarding collateral requirements, if any, for the deposit of public funds” and “if applicable, guidelines for contractual arrangements for the custody and safekeeping of that collateral.” 30 ILCS 235/2.5. The Illinois State Treasurer’s Office’s offers a template for local governments to use, the Sample Investment Policy for Local Governments.

The State Treasurer’s Office has posted its own Investment Policies and List of Financial Assets Qualified for Collateral to Secure Deposits and Repurchase Agreements, which detail the State Treasurer’s collateral requirements, but each public agency may have a different policy. As to State Treasurer funds, there are no limits on certificates of deposit, either in the formal or as an informal policy. We confirmed this with the State Treasurer’s office, and further learned that no state money is currently invested in C.D.s (likely due to the low rates of return). Notably, C.D.s are the only type of collateral for which the Public Funds Investment Act imposes particular requirements on the issuing institution (that it have a certain rating, asset level, and capital ratio). 30 ILCS 235/6(d)(9). (The Deposit of State Moneys Act repeats the same requirements as to deposits of state treasurer funds. See 15 ILCS 520/11.1.)