Since 2021 title industry cease and desist orders, ILTA has been in ongoing communication with the Illinois Department of Financial and Professional Regulation (IDFPR) regarding changes and enforcement related to the APLD compliance (click here for November 2021 letter to IDFPR).
***Upload Limits & Expired Applications***
In addition to clarification updates on the department’s FAQ page (click here), IDFPR more recently agreed to increase the 500 KB upload limit; ILTA has requested up to at least 2MB for uploads and we are working on a timeline for implementation.
As a result of ILTA joint committee working group discussions, there was also consensus regarding the issue of an APLD expiration timeframe; the problem occurs when applications can expire before many transactions close so ILTA has requested that the APLD expiration timeframe be changed to at least 120 days and if possible, up to one year.
***Help Needed – APLD Examples***
While IDFPR is open to consider other items requested in ILTA’s November 2021 letter to the department (click here), IDFPR has requested more information to better understand how the APLD portal may be changed.
Industry feedback is needed with specific examples and, if possible, screenshots not containing non-public information. In particular, there appears to be two aspects of the APLD portal that may not be the same or clear between the online input screens used by the title industry and lending industry:
- Loan originator system input lines are not identical to title industry input; and
- Input requirements for points and fees and miscellaneous data are not uniformly defined.
Specific examples and screenshots not containing non-public information are essential to obtaining APLD portal clarity that will help avoid future cease and desist orders along with the accompanying compliance audit and fine costs. Please email email@example.com with your information.