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* 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superseded or made obsolete by statutory or regulatory changes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6 (repealed) IBA |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. |
