Topic: Qualified Thrift Lender (QTL) Test
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As an Illinois-chartered savings bank, what are the consequences for failing to pass the qualified thrift lender test?
Neither the Illinois Savings Bank Act nor the corresponding administrative rules establishes specific consequences for a savings bank’s failure to meet one of the applicable asset tests. When we posed this question to an IDFPR attorney, we were told that this is a rare situation, for reasons explained below. Were this situation to arise, the…