We acquired a bank that performs certain vehicle license services to customers and non-customers for a flat fee. For example, they issue temporary vehicle registrations. Can banks provide these types of services?

Yes, Illinois law permits banks to issue vehicle registration plates and stickers, as well as conduct a variety of other vehicle registration and title services. The Illinois Secretary of State (SOS) has established an electronic registration and titling (ERT) program through which banks may contract with one of five approved service providers to transmit applications for titles and registration of motor vehicles, renew motor vehicle registrations, create and remove liens from motor vehicle records, apply for salvage or junking certificates, and sell registration plates and stickers directly to the public. The list of approved service providers is included in our resources below.

Note that there are limitations on the fees banks may charge for their vehicle registration and title-related services. For example, banks may not charge more than $7.50 for vehicle renewal license plates or stickers. In addition, fees for all other ERT services are limited to $25, “in addition to any other fee permitted by law or rule.” We are not aware of other laws or rules regarding permissible fees for these services, so we believe it would be prudent to adhere to the $25 fee limitation.

For resources related to our guidance, please see:

92 Ill. Admin. Code 1010.245(a) (“The Secretary may, in his or her discretion, establish a program for the electronic registration and titling (ERT) of motor vehicles. Transactions that may be conducted pursuant to an ERT program may include transmitting applications for titles and registration of motor vehicles, renewal of motor vehicle registrations, creating and removing liens from motor vehicle records, applying for salvage or junking certificates, and issuing registration plates and stickers by motor vehicle dealers, financial institutions and retail merchants . . . .”)
92 Ill. Admin. Code 1010.245(b) (“Upon the establishment of an ERT program, the Secretary may enter into agreements with ERT service providers to serve as intermediaries between the Secretary of State’s office and motor vehicle dealers, financial institutions and retail merchants (collectively referred to in this Section as ‘vendors’). For the purposes of this Section, the term ‘financial institution’ shall mean any federal or state chartered bank, savings and loan, credit union, and armored carrier, and any currency exchange, either directly or indirectly through an armored carrier.”)
92 Ill. Admin. Code 1010.540(a) (“Over-the-Counter Sales Program. In addition to any fee set forth in subsection (b), an entity participating in the over-the-counter program may charge an applicant for motor vehicle renewal license plates and/or stickers $7.50. No additional charge shall be imposed upon the applicant by any such person, firm, corporation or private institution, or its authorized agent for distribution of motor vehicle renewal license plates and/or stickers. The term Financial Institution, for the purposes of this Section, shall mean any federal or State chartered bank, savings and loan, credit union, armored carrier, and any currency exchange either directly or indirectly through an armored carrier.”)
92 Ill. Admin. Code 1010.425(b)(1) (“Vendors participating in the Electronic Registration and Titling (ERT) program may charge customers a fee for the optional service of electronically processing their vehicle titling and registration or data and for providing registration plates or stickers. The maximum fee to be imposed upon a customer utilizing the ERT services shall be $25, in addition to any other fee permitted by law or rule. However, if the ERT services are used solely for renewing vehicle registrations, the maximum fee imposed shall be that set forth is subsection (a). The actual ERT fee allowed to be charged by vendors shall be set out in the agreement between the Secretary of State and the ERT service provider and in the agreements between the ERT service provider and the vendors. . . .”)
92 Ill. Admin. Code 1010.425(b)(2) (“A service provider may charge vendors up to $10 for each ERT transaction. The maximum ERT fee to be imposed on the customer may not exceed the amount actually charged by the service provider to the vendor plus an amount equal to 1.5 times the amount actually charged by the service provider to the vendor, and, therefore, the maximum fee to be imposed upon a customer utilizing the ERT services shall be $25, in addition to any other fee permitted by statute or rule.”)
Illinois SOS, Electronic Registration and Title (ERT) Services Providers