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2000 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* Interpretive Letter superseded or made obsolete by statutory or regulatory changes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
00-01 01/03/00

5(11) & 34(4) IBA

When a bank extends credit to commercial equipment leasing company under a "Without Recourse" note with the leasing company, the lending limit and obligation for repayment will attach to the lessee rather than the leasing company. 

00-02 01/12/00 5(25) IBA Scope and effect of  "Super Wild Card" enacted by the "Banking on Illinois Act."
00-03 05/09/00 5(25) IBA

Bank may construct a building on property owned by the Bank and lease the building to the Post Office based on the authority of a federally insured thrift or certain out-of-state banks to engage in real property leasing. The Bank will be subject to any restrictions or limitations applicable to a federal thrift or out-of-state bank engaging in real property leasing. In addition, the Bank will need to seek approval from the FDIC.

00-04 06/06/00 3 & 5(11) IBA; 1-8 SLA;  1006(e), 1008(a)(25)&(26) and 6002(11) SBA An Illinois state bank, state savings bank or state savings and loan association may exchange stock that it holds in an EFT network for stock in the corporation into which the network merged which entity was engaged in the same activities as the EFT network and which will be engaged in the same permissible activities after the merger.
00-05 07/31/00 5(9) IBA A state bank may dispose of other real estate owned by any transaction that is a sale under accepted accounting principles, including selling the real estate pursuant to a land contract or a contract for deed.  Disposal may also be made by a donation of the real estate, but may not be conditioned by a potential reversion.
00-06 07/31/00 5(7) IBA State banks may utilize letters of credit issued by a Federal Home Loan Bank as collateral for the deposit of public funds.
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