If you are a federally chartered institution or a state-chartered institution in any state OTHER than Illinois, you can stop reading here unless you are interested.
Like some other states, Illinois passed their own Community Reinvestment Act statute in March of 2021 which can be found at 205 ILCS 735. Part of that law requires a notice posted on the Bank’s website and in lobbies of any IL chartered banks, credit unions and mortgage companies. The statute contains text for that notice.
Alternative language was provided by the Division of Banking in May 2021 for institutions which have not undergone a State CRA examination. Most institutions, for which TCA has reviewed signage, utilize one of these forms on their website and lobbies.
While TCA does not normally opine on State regulations, we wanted to make you aware of the change in signage requirements under the Illinois CRA regulation.
In October 2024, the Division of Banking issued a memo which superseded the May 2021 notice. In discussion with the Division of Banking at a recent Chicagoland regulator panel, the signage which should be used is the language found in Appendix B of Title 38, Section 345 of the Illinois Administrative Code. This language does not match the statute but instead mirrors the current language found in the Federal CRA regulation (not to be confused with the updated Federal CRA regulation currently on hold by the courts).
There are two different forms of the signage: one for a main office, or if an interstate bank, at one branch in each state; and one form for a branch office inside IL. You can see samples at the end of this Special Release.
At this same regulatory panel, we were advised this language will likely change when the Regulation is updated to mirror the Federal CRA so keep this in mind if getting expensive signage is on your mind.
This also impacts the required notice on the Bank’s public website. Section 345.430 states that the Appendix B signage shown below is also the required website notice. The Bank should update their lobby notice and website appropriately.
For the notices below:
- Items in Italics should be customized to the Institution (ie. name, contact, address, bank holding company)
- Text in brackets “[ ]” should only be included if applicable to the Institution (ie. holding company)
- Text in braces/curly brackets “{ }” should only be included if the Bank has multiple assessment areas.
MAIN OFFICE/WEBSITE NOTICE
Illinois Community Reinvestment Act Notice
Under the Illinois Community Reinvestment Act (ILCRA), the Secretary of the Department of Financial and Professional Regulation (Secretary) evaluates our record of helping to meet the credit needs of this community consistent with safe and sound operations. The Secretary also takes this record into account when deciding on certain applications submitted by us.
Your involvement is encouraged.
You are entitled to certain information about our operations and our performance under the ILCRA, including, for example, information about our branches, such as their location and services provided at them; the public section of our most recent ILCRA Performance Evaluation, prepared by the Secretary; and comments received from the public relating to our performance in helping to meet community credit needs, as well as our responses to those comments. You may review this information today.
At least 30 days before the beginning of each quarter, the Secretary publishes a list of the banks that are scheduled for ILCRA examination in that quarter. This list is available from the Secretary at 320 West Washington Street, 3rd Floor Springfield, IL 62786 and 555 West Monroe Street, Suite 500 Chicago, IL 60661. You may send written comments about our performance in helping to meet community credit needs to name and address of official at bank and Secretary. You may also submit comments electronically through the Department’s Web site at https://idfpr.illinois.gov/admin/cra.html. Your letter, together with any response by us, will be considered by the Secretary in evaluating our ILCRA performance and may be made public.
You may ask to look at any comments received by the Secretary. You may also request from the Secretary an announcement of our applications covered by the ILCRA filed with the Secretary.
[We are an affiliate of name of holding company, a bank holding company. You may request from the Officer in Charge of Supervision, Federal Reserve Bank of _______ address an announcement of applications covered by the ILCRA filed by bank holding companies.]
BRANCH OFFICE NOTICE
Illinois Community Reinvestment Act Notice
Under the Illinois Community Reinvestment Act (ILCRA), the Secretary evaluates our record of helping to meet the credit needs of this community consistent with safe and sound operations. The Secretary also takes this record into account when deciding on certain applications submitted by us.
Your involvement is encouraged.
You are entitled to certain information about our operations and our performance under the ILCRA. You may review today the public section of our most recent ILCRA evaluation, prepared by the Secretary, and a list of services provided at this branch. You may also have access to the following additional information, which we will make available to you at this branch within five calendar days after you make a request to us:
1) a map showing the assessment area containing this branch, which is the area in which the Secretary evaluates our ILCRA performance in this community;
2) information about our branches in this assessment area;
3) a list of services we provide at those locations;
4) data on our lending performance in this assessment area; and
5) copies of all written comments received by us that specifically relate to our ILCRA performance in this assessment area, and any responses we have made to those comments. If we are operating under an approved strategic plan, you may also have access to a copy of the plan.
{If you would like to review information about our ILCRA performance in other communities served by us, the public file for our entire bank is available at name of office located in state, located at address.}
At least 30 days before the beginning of each quarter, the Secretary publishes a list of the banks that are scheduled for ILCRA examination in that quarter. This list is available from the Secretary at 320 West Washington Street, 3rd Floor Springfield, IL 62786 and 555 West Monroe Street, Suite 500 Chicago, IL 60661. You may send written comments about our performance in helping to meet community credit needs to name and address of official at bank and the Secretary. You may also submit comments electronically through the Department’s Web site at https://idfpr.illinois.gov/admin/cra.html. Your letter, together with any response by us, will be considered by the Secretary in evaluating our ILCRA performance and may be made public.
You may ask to look at any comments received by the Secretary. You may also request from the Secretary an announcement of our applications covered by the ILCRA filed with the Secretary.
[We are an affiliate of name of holding company, a bank holding company. You may request from the Officer in Charge of Supervision, Federal Reserve Bank of _______ address an announcement of applications covered by the ILCRA filed by bank holding companies.]
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Here is a link to a Word template for the notices above.
TCA is your source for Federal regulatory compliance information. Contact us at (800) 934-7347 or at [email protected].
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