Yes, we recommend that Illinois-chartered banks post the required CRA notices in their offices and on their websites as soon as possible.

The Illinois CRA became effective immediately upon becoming law on March 23, 2021, including its requirement that covered financial institutions post public CRA notices in their public lobbies and on their websites. For this reason, we are currently recommending that covered financial institutions post the required notices to avoid violating the Illinois CRA.

However, we anticipate that the Illinois Department of Financial and Professional Regulation will soon begin issuing rules that will help clarify many aspects of the Illinois CRA, and we are expecting to receive guidance on the notice posting requirement that we will share with our members.

For more information, read the IBA’s Featured Development summarizing the new Illinois CRA on GotoIBA.com.

For resources related to our guidance, please see:

• Illinois CRA, 205 ILCS 735/35-20 (“Each covered financial institution shall provide, in the public lobby of each of its offices, if any, and on its website, a public notice that is substantially similar to the following:

STATE OF ILLINOIS COMMUNITY REINVESTMENT NOTICE

The Department of Financial and Professional Regulation (Department) evaluates our performance in meeting the financial services needs of this community, including the needs of low-income to moderate-income households. The Department takes this evaluation into account when deciding on certain applications submitted by us for approval by the Department. Your involvement is encouraged. You may obtain a copy of our evaluation. You may also submit signed, written comments about our performance in meeting community financial services needs to the Department.”)

• Illinois CRA, 205 ILCS 735/99-99 (“This Act takes effect upon becoming law. . . .”)