Premium fund trust accounts are fiduciary accounts (similar in that respect to lawyers’ IOLTA accounts). The Illinois Insurance Code regulations require any entity that has to be licensed under Title XXXI of the Insurance Code to hold most insurance premium payments in premium fund trust accounts. 50 Ill. Adm. Code 3113.40(c). 

The regulations impose several requirements on the accounts, some of which could impact the bank: Every premium fund trust account must be designated as a “Premium Fund Trust Account” in bank records and on the face of the checks of that account. 50 Ill. Adm. Code 3113.40(b). Account funds can be placed in certain types of accounts and investments (including checking and savings accounts), provided that the insurance company has given its written authorization (with a sample form provided here). 50 Ill. Adm. Code 3113.40(k). Otherwise, the obligations of a premium trust fund account fall on the licensee that is responsible for the account.