The Illinois Department of Financial and Professional Regulation (IDFPR) hasn’t updated its criteria for crimes that are considered de minimis since the FDIC’s update. The IDFPR’s most recent update was in 2005, with the publication of its Policy Statement 1009 — Guidance Concerning the Employment Practices of Regulated Institutions. We recently spoke to an attorney at the IDPFR, and he told us that they have no plans to update their Policy Statement in the near future.

Also note that financial institutions must submit applications to the IDFPR for every individual that has a criminal history, even if the individual’s offense meets the de minimis criteria. This is in contrast to the FDIC’s Policy Statement, which does not require an application for individuals with de minimis offenses.