The Predatory Lending Database Program (765 ILCS 77/70) was enacted in 2008 and established in Cook County to reduce predatory lending practices by assisting borrowers in understanding the terms and conditions of loans for which they have applied. It was expanded in 2010 to include Kane, Peoria, and Will Counties.
The Program applies to 1-4 unit, owner-occupied residential mortgage loan applications and data regarding mortgages closed in Cook, Kane, Peoria, and Will Counties. Every mortgage filed in the program counties must have a certificate attached – either a Certificate of Compliance, or a Certificate of Exemption, depending on the entity closing the transaction.
Credit unions and their employees are statutorily exempt from reporting to the database and from related requirements – but credit unions are required to file a Certificate of Exemption with the County Recorder, regarding mortgage loans made within the program area, if the credit union closes its own transactions.
CUSOs licensed as residential mortgage licensees have to fully comply by reporting information to the database whenever the CUSO acts as originator, broker, or closing agent regarding a residential mortgage loan within the program area (i.e., whenever the CUSO solicits, processes, places, or negotiates the loan or application) – and by filing a Certificate of Compliance with the County Recorder, regarding mortgage loans made within the program area that the CUSO closes.
Other non-exempt entities that are loan originators, brokers, counselors, title insurance companies, or closing agents also must provide detailed loan information to the database — and file a Certificate of Compliance with the County Recorder, regarding mortgage loans that they close within the program area.
Certificate of Exemption
The Certificate of Exemption is a filing requirement for exempt entities, including credit unions. Credit unions that need an Exemption Certificate must obtain their Certificates from the Department of Financial and Professional Regulation through the following website: www.ilapld.com. The website refers to the program as the Illinois Anti-Predatory Lending Database Program. Credit unions need a user ID and password to print out a Certificate of Exemption. As of September 13, 2023, all users of the Anti-Predatory Lending Database are required to use multi-factor authentication (MFA) when accessing the database, and will need to use either the Google Authenticator or Microsoft Authenticator on a mobile device. Device setup instructions and Frequently Asked Questions will be available on the MFA set up page. There is a phone number and email address for any questions about the MFA: The customer service number is 1-888-455-2753, and the email address is [email protected].
For further information about items in this L & T Bulletin, please contact ICUL’s Compliance & Advocacy Office: