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One of our vendors believes that we need to use a form required by the Illinois Residential Mortgage License Act of 1987, but I don’t think that law applies to financial institutions. Do you agree? – IBA Compliance Connection

One of our vendors believes that we need to use a form required by the Illinois Residential Mortgage License Act of 1987, but I don’t think that law applies to financial institutions. Do you agree?

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We agree that the Illinois Residential Mortgage License Act of 1987 does not directly apply to financial institutions. Section 1-3 states that the Act does not apply to an institution that is considered an “exempt person or entity.” 205 ILCS 635/1-3(a). The term “exempt person or entity” is defined to include “any bank, . . . savings bank, or credit union,” as well as their employees.  205 ILCS 635/1-4(d). However, if your organization has subsidiaries that are not banks, you will have to determine whether the Act’s restrictions apply to them.