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?
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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…