Illinois Department of Financial & Professional Regulation Illinois Department of Financial & Professional Regulation
Bryan A. Schneider, Secretary  
Bruce Rauner, Governor
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2001 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* Interpretive Letter superseded or made obsolete by statutory or regulatory changes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
01-01 3/9/2001

Section 48(1)

Scope and effect of Section 48.1 of the Illinois Banking Act as compared to the federal privacy regulations enacted pursuant to the Gramm-Leach-Bliley Act

01-02 4/26/2001 Section 32 IBA A loan to an LLC is not aggregated with a loan to another commonly owned LLC, provided each has sufficient collateral and income to justify the loans.
01-03 7/9/2001 Section 32 IBA

A loan to the shareholders of a corporation or to another business entity owned by those shareholders is not aggregated with the borrowings of the corporation, unless the Bank is looking to the corporation for repayment.

01-04 3/18/2002 Section 32 IBA A loan to a land trust is not aggregated with the individual borrowings of a beneficiary unless the bank is actually looking to the beneficiary for repayment.
01-05 4/11/2002 Section 32 IBA A loan to a shell corporation will be aggregated with the borrowings of another corporation when theultimate source of repayment is the other corporation.
01-06 5/01/2002 Section 5(11) IBA A state chartered bank may provide consumer deposit account holders with the required annual disclosure by electronic means. In addition, a state chartered bank or trust company may provide customers periodic account statements by electronic means.
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