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Did the federal Protecting Tenants at Foreclosure law expire on December 31, 2014? We realize the Illinois law is still in place, so how should we update our policy and procedures? – IBA Compliance Connection

IBA Compliance Connection

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Did the federal Protecting Tenants at Foreclosure law expire on December 31, 2014? We realize the Illinois law is still in place, so how should we update our policy and procedures?

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Yes, the Protecting Tenants at Foreclosure Act of 2009 expired on December 31, 2014. See the notes to 12 USC 5220Section 1484 of the Dodd-Frank Act (setting the December 31, 2014 sunset date). Last year, two bills were introduced to extend the sunset date (H.R. 3543 and S. 1761), but both bills died in committee.

Because the federal law could be interpreted as continuing to apply to ongoing foreclosures at your institution, we recommend waiting until those foreclosure actions are completed before removing references to the federal law in your policies and procedures.

As you noted, many provisions from the federal law remain in place in Illinois, as they have been imported into Illinois law. See the amendments to the Illinois Code of Civil Procedure in Public Act 98-514.