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Do loans which are 100% secured by a segregated cash deposit account held at our bank count against our lending limit under the Illinois Banking Act? – IBA Compliance Connection

IBA Compliance Connection

Your go to source for compliance!

Do loans which are 100% secured by a segregated cash deposit account held at our bank count against our lending limit under the Illinois Banking Act?

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No. Loans that are secured by a segregated deposit account at the lending institution are exempt from the Act’s lending limit.

For resources related to our guidance, please see below:

  • Illinois Banking Act — 205 ILCS 5/32 (general lending limit provisions)
  • Illinois Banking Act — 205 ILCS 5/35(7) (loans secured by deposits in a segregated cash deposit account exempt from lending limit)