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2010 Interpretive Letters

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KEY:

  • BCA means Business Corporation Act
  • BIA means Banking on Illinois Act
  • BSCA means Bank Service Corporation Act
  • CCIA means Credit Card Issuance Act
  • CDAA means Consumer Deposit Account Act
  • CFA means Corporate Fiduciary Act
  • CILA means Consumer Installment Loan Act
  • CPCNA means Check Printer and Check Number Act
  • EFTA means Electronic Fund Transfer Act
  • EFTTFA means Electronic Fund Transfer Transmission Facility Act
  • FBOA means Foreign Banking Office Act
  • FBROA means Foreign Bank Representative Office Act
  • IA means Interest Act
  • IBA means Illinois Banking Act
  • IBHCA means Illinois Bank Holding Company Act of 1957
  • IFSDA means Illinois Financial Services Development Act
  • IIC means Illinois Insurance Code
  • IUIA means Illinois Unemployment Insurance Act
  • LLCA means Limited Liability Company Act
  • PA means Probate Act
  • PRA means Pawnbroker Regulation Act
  • SBA means Savings Bank Act
  • SFAA means Securities in Fiduciary Accounts Act
  • SLA means Savings and Loan Act of 1985
  • TIA means Title Insurance Act
  • TTA means Trust and Trustees Act
  • UCC means Uniform Commercial Code
  • ULPA means Uniform Limited Partnership Act

* Interpretive Letter superseded or made obsolete by statutory or regulatory changes

Letter Number Date Issued Sections of Acts Construed
Description
10-01 4/5/2010

IBA
Section 5/48.1(a)(4)

Banks may invite employees of affiliated banks to attend their quarterly trust committee meetings.
10-02 6/15/2010 IBA
Sections 5/1, 4/(11), 5/5(12(c)
A bank may exchange property obtained in satisfaction of debt previously contracted for an equity interest in an entity which would manage, market, and dispose of the property pursuant to 205 ILCS 5/5(11) because it encompasses a permissible activity for national banks
10-03 7/1/2010 IBA
Section 5(17) and EFT Act Section 616/1

Branding agreements are permissible for state-chartered banks for the purpose of advertising on non-bank owned ATMs

10-4 7/2/2010 Title V of the Housing and Economic Recovery Act of 2008, 12 USCA 5101, et seq Employees of Illinois chartered banks and thrifts are not subject to licensure under the S.A.F.E. Act, but they must register with the NMLS

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