We expect to begin receiving credit applications from individuals who are currently receiving unemployment benefits. Is there a way to verify how long an individual will continue to receive such benefits, and is there any documentation from the State they can provide with this information?

To verify an applicant’s unemployment insurance (UI) benefits being administered by the Illinois Department of Employment Security (IDES), we recommend requesting a copy of their “UI Finding,” which indicates their weekly benefit amount (and dependent allowance, if applicable) and their maximum benefit balance.  

Generally, individuals in Illinois may not collect unemployment benefits for a period of more than twenty-six weeks in a one-year period. However, under the CARES Act, individuals who have exhausted their state unemployment benefits may be eligible for up to an additional thirteen weeks of Pandemic Emergency Unemployment Compensation (PEUC). Self-employed workers, freelancers or independent contractors who typically are not eligible for unemployment benefits may be eligible for up to 39 weeks of Pandemic Unemployment Assistance (PUA) if certain conditions are met. Under the CARES Act, the last week PEUC or PUA may be paid is the week ending December 26, 2020. Individuals receiving state or federal unemployment benefits also may be entitled to an additional $600 a week under the CARES Act for the period from March 29 through July 25, 2020.

This is not an exhaustive list of unemployment benefits for which an applicant may be eligible. To verify an applicant’s maximum unemployment benefit from an entity other than the IDES (which administers CARES Act-related benefits for individuals who worked in Illinois), we recommend reviewing copies of any documentation the applicant has received regarding their benefits from the agency that is administering them.

Additionally, we note that when determining a consumer’s debt to income ratio for qualified mortgage purposes, Regulation Z’s Appendix Q provides that unemployment income “must be documented for two years, and there must be a reasonable assurance that this income will continue.”

For resources related to our guidance, please see:

  • IDES, Unemployment Insurance Benefits Handbook, page 3 (“In Illinois, the unemployment insurance program is administered by IDES; services are provided to the public via the Internet and at IDES offices throughout the state.”)
  • IDES, Unemployment Insurance Benefits Handbook, page 10 (“After your claim is filed, IDES will send you a statement called a UI Finding. The Finding shows:
    • Your first certification date.
    • The wages you were paid by each employer in each calendar quarter of your base period for insured work.
    • Date of claim and benefit year begin and end dates.
    • Your weekly benefit amount (WBA) and dependent allowance*.
    • Your maximum benefit balance.”)
  • IDES, Unemployment Insurance Benefits Handbook, page 3 (“The program ensures that, if you meet the eligibility requirements of the law, you will have some income while you are looking for a job, up to a maximum of 26 full weeks in a one-year period.”)
  • Unemployment Insurance Act, 820 ILCS 405/607 (“Ineligibility after 26 weeks – Work requirement for second benefit year.

(A) An individual shall be ineligible for benefits whenever, in any period commencing with a compensable week of unemployment, he has been allowed his full weekly benefit amount for each of twenty-six weeks, until he has earned wages equal to at least three times his current weekly benefit amount in bona fide work, reduced by an amount equal to his current weekly benefit amount for each week, if any, in which he was not unemployed within such period, whereupon he shall again, if otherwise eligible, be permitted to receive his full weekly benefit amount for twenty-six weeks.’ . . .

(B) An individual shall be ineligible for benefits for any week in a benefit year which begins on or after January 1, 1972, unless, subsequent to the beginning of his immediately preceding benefit year with respect to which benefits were paid to him, he performed bona fide work and earned remuneration for such work equal to at least 3 times his current weekly benefit amount.”)

  • Illinois Department of Employment Security, FAQs (“I have exhausted my rights to UI. Will additional benefits be available because of the COVID-19 situation? Yes. Pandemic Emergency Unemployment Compensation (PEUC) is a temporary program that provides up to 13 weeks of benefits to individuals who have exhausted all rights to regular compensation with respect to a benefit year that ended on or after July 1, 2019. However, the first possible week for which PEUC may be paid is the week beginning March 29, 2020. The last week that PEUC may be paid is the week ending December 26, 2020. If an individual has exhausted benefits and is no longer certifying, IDES will determine eligibility, notify the claimant, and automatically enroll the claimant in PEUC.”)
  • CARES Act, Section 2107(a)(2), Pandemic Emergency Unemployment Compensation (“Any agreement under paragraph (1) shall provide that the State agency of the State will make payments of pandemic emergency unemployment compensation to individuals who—

(A) have exhausted all rights to regular compensation under the State law or under Federal law with respect to a benefit year (excluding any benefit year that ended before July1, 2019);

(B) have no rights to regular compensation with respect to a week under such law or any other State unemployment compensation law or to compensation under any other Federal law;

(C) are not receiving compensation with respect to such week under the unemployment compensation law of Canada; and

(D) are able to work, available to work, and actively seeking work.”)

  • CARES Act, Section 2107(b)(2), Pandemic Emergency Unemployment Compensation (“The amount established in an account under subsection (a) shall be equal to 13 times the individual's average weekly benefit amount, which includes the amount of Federal Pandemic Unemployment Compensation under section 2104, for the benefit year.”)
  • Illinois Department of Employment Security, FAQs (“I am self-employed. Do I qualify under the new federal unemployment program? Under regular unemployment rules, the incomes of self-employed workers, freelancers, and independent contractors are not subject to unemployment taxes and so typically these individuals are not eligible for unemployment benefits. Pandemic Unemployment Assistance (PUA) was created to help people who lose this type of work as a direct result of the current public health emergency. A precondition for approval is that someone is not eligible for other unemployment programs. Applying for and being denied benefits under the regular UI program can help establish eligibility under the new temporary program.”)
  • Illinois Department of Employment Security, FAQs (“What does “Reasons attributable to COVID-19” mean? PUA provides up to 39 weeks of benefits to qualifying individuals who are otherwise able to work and available for work, except that they are unemployed, partially unemployed, or unable or unavailable to work due to one of the COVID-19 related reasons listed below . . .”)
  • CARES Act, Section 2102(c)(2), Pandemic Unemployment Assistance (“The total number of weeks for which a covered individual may receive assistance under this section shall not exceed 39 weeks and such total shall include any week for which the covered individual received regular compensation or extended benefits under any Federal or State law, except that if after the date of enactment of this Act, the duration of extended benefits is extended, the 39-week period described in this paragraph shall be extended by the number of weeks that is equal to the number of weeks by which the extended benefits were extended.”)
  • Illinois Department of Employment Security, FAQs  (“How long will Pandemic Unemployment Assistance last? Will my PUA claim be backdated? PUA payments are available for claimants who were unemployed due to COVID-19 related reasons beginning the week of February 2, 2020. PUA payments end on December 26, 2020. IDES will backdate claims to the first week of unemployment due to COVID-19 related reasons.”)
  • Illinois Department of Employment Security, FAQs (“Who is eligible for the additional $600? Anyone who receives at least $1 of state or federal unemployment benefits for a week, during the period from March 29, 2020 through July 25, 2020. Are self-employed individuals receiving assistance under the Pandemic Unemployment Assistance program eligible for the additional $600? Yes, for the duration of the FPUC program. Once my application is processed and I begin receiving my unemployment benefits, will I also receive the additional $600 at the same time? Yes, for the duration of the FPUC program. Under federal law, anyone eligible for at least a $1 in benefits for a week will be eligible for the $600 extra. The first week for which FPUC may be paid is the week beginning March 29, 2020; and the last week that FPUC may be paid is the week ending July 25, 2020.”)
  • CARES Act, Section 2104(b)(1), Federal Pandemic Unemployment Assistance (“Any agreement under this section shall provide that the State agency of the State will make payments of regular compensation to individuals in amounts and to the extent that they would be determined if the State law of the State were applied, with respect to any week for which the individual is (disregarding this section) otherwise entitled under the State law to receive regular compensation, as if such State law had been modified in a manner such that the amount of regular compensation (including dependents’ allowances) payable for any week shall be equal to—

(A) the amount determined under the State law (before the application of this paragraph), plus

(B) an additional amount of $600 (in this section referred to as “Federal Pandemic Unemployment Compensation”).

  • U.S. Department of Labor, Unemployment Insurance Relief During COVID-19 Outbreak (“The Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law on March 27. It expands states’ ability to provide unemployment insurance for many workers impacted by the COVID-19 pandemic, including for workers who are not ordinarily eligible for unemployment benefits.  . . . To receive unemployment insurance benefits, you need to file a claim with the unemployment insurance program in the state where you worked.”)
  • Regulation Z, Appendix Q, Standards for Determining Monthly Debt and Income, (2C)(3)(c) (“Unemployment income must be documented for two years, and there must be reasonable assurance that this income will continue. This requirement may apply to seasonal employment.”)