No, the Illinois notice of a mortgage servicing transfer does not supersede the federal notice required by the Real Estate Settlement Procedures Act (RESPA) and Truth in Lending Act (TILA). Consequently, you should provide either a combined notice that encompasses both the federal and Illinois requirements or separate federal and Illinois notices.

It would be appropriate to use a combined notice using a federal form, provided that it includes the additional information required by the Illinois Banking Act. Regulation Z permits mortgage servicing transfer notices to be “combined with other materials or disclosures, including the transfer of servicing notices required by the Real Estate Settlement Procedure Act.”

For resources related to our guidance, please see:

• Illinois Banking Act, 205 ILCS 5/48.2(e) (Requires banks to provide a servicing transfer notice within 45 days “if the servicing of a residential mortgage shall be transferred from the original mortgagee . . . which notice shall set forth: the name and address of the transferee; the name, address and telephone number to which inquiries by the residential mortgagor should be addressed; and the name and address to which the next 3 monthly installments are to be submitted to the transferee and the amount of each of such monthly installment; . . .”)

• Official Interpretations, Regulation Z, 12 CFR 1026, Paragraph 39(b)(1), Comment 1 (“COMBINING DISCLOSURES. The disclosures under this section can be combined with other materials or disclosures, including the transfer of servicing notices required by the Real Estate Settlement Procedure Act (12 U.S.C. 2601 et seq.) so long as the combined disclosure satisfies the timing and other requirements of this section.”)