IBA Compliance Connection

Your go to source for compliance!

We are aware that the IDFPR issued a Supervisory Statement regarding the Illinois Community Reinvestment Act (CRA) that includes revised language for the public notice requirement. May we still use the public notice language in the Illinois CRA to avoid purchasing additional signage later?

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Yes, we believe you may post a public notice containing the language set forth in Section 35-20 of the Illinois CRA. While the IDFPR’s Supervisory Statement indicates that it will consider the revised language referenced in the statement to be “substantially similar” to the notice provided in the statute, it does not require covered financial institutions to use the revised language.

For resources related to our guidance, please see:

  • Illinois CRA, 205 ILCS 735/35-20 (“Public notice. 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.’”)
     

  • IDFPR, Illinois Community Reinvestment Act Supervisory Statement (May 5, 2021) (“[T]he Division of Banking (DOB) has yet to issue evaluations for DOB covered financial institutions. Accordingly, while this Statement remains in effect, DOB will consider the following notice substantially similar to the notice shown above:

    ‘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 once the Department completes our first evaluation. You may also submit signed, written comments about our performance in meeting community financial services needs to the Department. We will update this notice when our first evaluation has been issued.’”)