IBA Compliance Connection

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Are banks subject to the Illinois Residential Mortgage License Act of 1987? We were told that we need to provide a Borrower Information Document to mortgage loan applicants under the Act.

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No, the Illinois Residential Mortgage License Act of 1987 does not apply to financial institutions. The Act exempts “any bank . . . savings bank, or credit union.” However, if your institution has subsidiaries or affiliates that are not banks, they are not covered by this exemption.

For resources related to our guidance, please see:

  • Residential Mortgage License Act of 1987, 205 ILCS 635/1-3(a) (the Act does not apply to an institution that is considered an “exempt person or entity”)
  • Residential Mortgage License Act of 1987, 205 ILCS 635/1-4(d) (“exempt person or entity” includes “any bank . . . savings bank, or credit union”)