IBA Compliance Connection

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We are aware that vehicle repossessions had previously been suspended under COVID-related Illinois executive orders. Have banks been allowed to resume vehicle repossessions as of October 29, 2020?

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Yes, banks have been allowed to resume vehicle repossessions since August 23, 2020. On July 24, 2020 the Illinois governor issued Executive Order 2020-48, which rescinded the suspension on vehicle repossessions after August 22, 2020. Subsequent executive orders have not extended the suspension of vehicle repossessions in Illinois.

For resources related to our guidance, please see:

  • Illinois Executive Order 2020-48 (July 24, 2020) (“Executive Order 2020-16 is re-issued in its entirety and extended through August 22, 2020, whereafter Section 1 shall be rescinded.”)
  • Illinois Executive Order 2020-16 (March 28, 2020) (“Section 1. Beginning March 27, 2020 and continuing for the duration of the Gubernatorial Disaster Proclamation, the provisions of the Uniform Commercial Code, 810 ILCS 5/9-609, regarding the possession or usability of a vehicle, and the provisions of the Illinois Vehicle Code, 625 ILCS 5/3-114, regarding the repossession of vehicles, are suspended. . . .”)