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Bryan A. Schneider, Secretary  
Bruce Rauner, Governor
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2002 Interpretive Letters

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  • 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* Interpretive Letter superseded or made obsolete by statutory or regulatory changes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
02-01 01/16/2002

Section 3 IBA


Section 32 IBA



Section 5 TTA



Section 21-2.06 Probate Act

State bank may sell certificates of deposit with returns based on the performance of an established equity market index.  Bank also may engage in related interest rate risk hedging through swap contracts with the Federal Home Loan Bank.

State bank may purchase certificates of deposit with returns based on the performance of an established equity market index.  However, such purchases may not exceed the basic loaning limits of Section 32.


Pursuant to an Illinois Attorney General's Opinion, a state bank's purchases of certificates of deposit may not exceed the basic loaning limits of Section 32.


Illinois corporate fiduciary may invest trust assets in certificates of deposit with returns based on the performance of an established equity market index.


Illinois corporate fiduciary is not permitted to invest a ward's assets in certificates of deposit that earn interest contingent on the performance of an established equity market because such interest in not FDIC-insured until maturity.

02-02 3/11/2002 Section 5 (25) Bank may engage in a contractual deposit-taking relationship with a nonaffiliated bank, subject to certain conditions.
02-03 3/11/2002 Section 33

Pawnbroker may conduct limited courier services incidental to licensed activity.

02-04 3/18/2002 Section 32 (3) For purposes of the lending limit exemption under Section 32 (3) of the Illinois Banking Act, both appraisers must meet minimum federal standards of licensure or certification in order to be "qualified".
02-05 4/11/2002 Section 48.3 (b)(5) Bank may provide confidential supervisory information to insurance carrier for purposes of obtaining or renewing bond coverage, subject to conditions.
02-06 5/01/2002 Sections 3, 5(11), 32 and 33 IBA National wildcard authority contained in Section 5(11) of the IBA provides for State banks to purchase and hold Trust Preferred Securities as loans.
02-07 6/11/2002 Sections 3 and 5(11) IBA A state bank may purchase and hold the minimum amount of Federal Home Loan Bank stock in order to become a member. A state bank may also purchase and hold Federal Home Loan Bank stock in excess of the minimum required for membership, but only in limited circumstances and subject to the same conditions and limitations imposed on a national bank.
02-08 6/12/2002 Section 43 IBA Board of Directors may use electronic mail to conduct business of the bank.
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