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APLD EXEMPTION UPDATE
Industry Update: Public Act 103-1015 clarifies that persons or entities exempt from licensure under the Residential Mortgage License Act of 1987 (RMLA) are exempt from the requirements of the Anti-Predatory Lending Database (APLD). Public Act 103-1015 amends the Residential Real Property Disclosure Act (RRPDA), which governs the APLD.
Effective January 1, 2025, the definition of exempt person or entity in Section 70(a) of the RRPDA is amended to specifically exempt all persons or entities exempt under Section 1-4(d) of RMLA. Previously, only those persons or entities exempt under subsections (1), (1.5), and (1.8) of Section 1-4(d) of RMLA were specifically exempt from APLD requirements. Public Act 103-1015 clarifies that exempt persons or entities under all other subsections of Section 1-4(d) are also exempt from APLD requirements. Public Act 103-1015 can be found here: Illinois General Assembly - Full Text of Public Act 103-1015.
Change in Housing Counseling Notice Procedure
When IDFPR determines that housing counseling is required under the APLD, the borrower will now receive a housing counseling notice from the Department by email, rather than by regular mail. IDFPR will send the notice to the borrower from the following email address: noreply@ILAPLD.com.
If you enter borrower email addresses into the APLD, please be sure to type the email addresses carefully. If a borrower does not use email, please leave the email field blank and IDFPR will send the borrower the housing counseling notice by regular mail. The borrower’s email address is not a required field of APLD data entry. However, entering a borrower’s email address will enable them to quickly receive the housing counseling notice. If you have entered a loan into the APLD that requires housing counseling, you should advise the borrower to be expecting the housing counseling notice.
If you have any questions, please contact APLD Customer Service at 888-455-2753, or by email at service@ilapld.com.
