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A county requested a 48-month certificate of deposit at our bank. Is that permissible in Illinois? – IBA Compliance Connection

IBA Compliance Connection

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A county requested a 48-month certificate of deposit at our bank. Is that permissible in Illinois?

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We are not aware of any term limits under Illinois law, but the answer depends on the individual public agency’s investment policy. All public agencies must adopt written investment policies, including “guidelines regarding collateral requirements, if any, for the deposit of public funds” and “if applicable, guidelines for contractual arrangements for the custody and safekeeping of that collateral.” 

We also note that certificates of deposit are the only type of collateral for which the Public Funds Investment Act imposes particular requirements on the issuing institution (that it have a certain rating, asset level, and capital ratio). The Deposit of State Moneys Act repeats the same requirements as to deposits of state treasurer funds. 

For resources related to our guidance, please see:

  • Public Funds Investment Act, 30 ILCS 235/2.5 (requires each public agency to adopt a written investment policy and outlines guidelines for the policy)
  • Public Funds Investment Act, 30 ILCS 235/6(d)(9) (outlines requirements for institutions issuing certificates of deposits to public agencies)
  • Deposit of State Moneys Act, 15 ILCS 520/11.1 (outlines requirements for institutions issuing certificates of deposits to public agencies)