Anti-Predatory Lending Database
Since ILTA’s August 2020 Anti-Predatory Lending Database (APLD) webinar (click here), the association has continued to work on clarifications and online platform changes to help with industry compliance.
In the fall of 2020 the Illinois Department of Financial and Professional Regulation (IDFPR) provided FAQ updates in response to some industry concerns (click here).
Industry conversations have continued with IDFPR, and in the summer of 2021, the state transitioned from APLD Manager Katie Liss to Michael Garvin (firstname.lastname@example.org).
In the fall of 2021, ILTA compiled a list of recommendations for regulatory changes (click here), of which IDFPR indicated interest in moving forward with several areas; however, specific industry examples of these recommendations have been requested by IDFPR.
CLICK HERE to register for ILTA’s joint committee APLD working group meeting on May 6th (open to settlement services, title counsel, legislative committee members) to help finalize examples and specific recommendations regarding numerous APLD regulatory concerns:
- Loan originator system input lines are not identical to title industry input;
- Input requirements for points and fees and miscellaneous data are not uniformly defined;
- Input corrections are not allowed;
- Applications expire before many transactions close;
- System does not allow users to run reports for purposes of self-compliance audits;
- System limits closing disclosure upload to 500 KB; and
- Loan originators can no longer input PINs (parcel index numbers).