Illinois Department of Financial & Professional Regulation Illinois Department of Financial & Professional Regulation
Bryan A. Schneider, Secretary  
Bruce Rauner, Governor
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1980 - 1989 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* Interpretive Letter superseded or made obsolete by statutory or regulatory changes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 Description
80-01 01-29-80 5(7) IBA Policemen and Firemen's Pension Funds are "public funds" for which a state bank may pledge assets to secure deposits.
83-01 11-30-83 3, 5(12) and 35.2 IBA State bank may act as futures commission merchant and establish subsidiary to act as futures commission merchant.
85-01 01-16-85 5(15), 6 (repealed) IBA State bank may arrange independent messenger service for customers, but may not set routes or process billings which include charges imposed by the bank for arranging the service.
85-02 03-04-85 5(15)(g) IBA *
85-03 04-19-85 48.1 IBA State bank may reveal customer information to its bonding company in order to process a claim.
85-04 04-26-85 5(16) IBA Bank that only services ATMs is not establisher of the ATMs.
85-05 10-30-85 32 IBA Customer may borrow up to a state bank's lending limit and separately guarantee a loan up to the bank's limit for total "money borrowed or otherwise" to one person.
85-06 12-06-85 35.2 IBA Purchase by a state bank of certificate of deposit from another bank is limited to 10% of capital, surplus and undivided profits when the second bank is owned by a bank holding company owned by two persons, one of whom controls 30% of the first bank.
86-01 04-10-86 33 IBA State bank may not invest in tax certificates on property in which bank has no security interest.
86-02 10-24-86 3 and 5(11) IBA State bank may be limited partner in Small Business Investment Corporation and invest up to 5% of its capital and surplus in it.
86-03 12-24-86 5(15) and 17(2) IBA *
87-01 01-16-87 35.2 IBA Loan from unaffiliated party to purchase stock of the bank holding company which owns the bank is a "covered transaction" subject to the restrictions on loans to affiliates.
87-02 01-27-87 5(11) IBA State bank may invest in securities issued by Student Loan Marketing Association (Sallie Mae) and Federal National Mortgage Association (FNMA) to the same extent as national banks.
87-03 03-19-87 32 IBA, 3-105(1)(h) UCC *
87-04 04-09-87 35.2 IBA State bank may not sell participation in credit card receivables to its affiliated state bank because past due accounts included in portfolio are low quality assets and proposed transaction is not a true participation.
88-01 02-01-88 4-2 CFA *
88-02 02-05-88 5(15) IBA *
88-03 06-29-88 33 IBA Mutual income fund that invests in limited partnerships engaged in general business is not a permitted investment.
88-04 09-27-88 3 IBA State bank's proposed collection services do not constitute activities of a bill collection agency.
88-05 09-30-88 5(15) IBA State bank may not operate messenger service for bank's customers that utilizes bank's employees.
88-06 10-11-88 5(10) State bank may make a capital contribution to the Federal Agricultural Mortgage Corporation ("Farmer Mac") in exchange for stock in order to participate in Farmer Mac's secondary market program.
88-07 12-13-88 2 IBA National bank located in Illinois may establish loan production office.
88-08 12-28-88 4.05(a)(2) BCA, 46 IBA Use of the terms "bancorp, bancorporation or bancshares" does not violate prohibition against use of the terms "bank, banker or banking."
89-01 01-19-89 2(g) and 3.02 IBHCA Voting trust created by family members that control a state bank is a bank holding "company."
89-02 01-30-89 5(12) and 5(15) IBA *
89-03 02-22-89 5(15)(g) IBA *
89-04 03-01-89 5(7) IBA State bank that pledges securities to secure deposits of public funds may hold such securities for safekeeping in an out-of-state bank or in an affiliated trust company.
89-05 03-29-89 3 and 5 IBA State bank may purchase certificates of deposit and government securities as agent for its customers and charge a fee for this service as part of its general banking business.
89-06 04-04-89 48.2 IBA State bank may sell credit life, accident and health insurance, but may not receive commissions for this service.
89-07 06-18-89 3 IBA State bank may provide limited financial advisory services to unaffiliated parties in connection with mergers and acquisitions as part of its general banking business.
89-08 06-28-89 48.1 and 48.3 IBA State bank is not authorized to produce examination report pursuant to a "Request to Produce" issued to it in litigation.
89-09 08-29-89 33, 34 and 35 IBA State bank may engage in fixed coupon dollar repo and dollar roll transactions subject to satisfying the criteria established for national banks by the Office of the Comptroller of the Currency.
89-10 08-31-89 3 IBA State bank may offer discount brokerage services through affiliation with a registered broker.
89-11 08-31-89 37 IBA State bank may extend loan secured by stock of its bank holding company without violating prohibition against making a loan secured by bank's own stock.
89-12 10-19-89 37(2) IBA State bank may not extend line of credit secured by a reverse repurchase agreement collateralized by the bank's own pledge of its government securities.
89-13 10-25-89 16(4) IBA *
89-14 11-3-89 40 IBA *
89-15 11-16-89 18 IBA Corporate reorganization does not result in change of control requiring the filing of an application for a change of control.
89-16 12-28-89 5(21) IBA State bank investment in limited partnership that invests in condominiums rented to disabled and low income residents is authorized by Section 5(21) of the Illinois Banking Act.
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