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We know that the Illinois grace period notice requirement was permitted to sunset on July 1, 2016. We plan to remove it from our delinquency notice insert, but want to confirm whether there is any pending legislation that may reinstate it retroactively. – IBA Compliance Connection

We know that the Illinois grace period notice requirement was permitted to sunset on July 1, 2016. We plan to remove it from our delinquency notice insert, but want to confirm whether there is any pending legislation that may reinstate it retroactively.

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We are not aware at this time of any efforts to reinstate the grace period notice requirement in the law, although it remains possible that the General Assembly may reinstate it at a later date. Whether you wish to discontinue sending the grace period notice to borrowers who became delinquent on or after July 1, 2016, is a business decision for your institution to make, but your bank should be aware that this change may be temporary.

For resources related to our guidance, please see:

  • Code of Civil Procedure, 735 ILCS 5/15-1502.5 (Illinois grace period notice requirement, with a sunset date of July 1, 2016.)