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ARTICLE · 27 AUGUST 2025

Illinois Proposes Regulations Governing Shared Appreciation Agreements

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Illinois continues to move forward in regulating "shared appreciation agreements." On August 15, 2025, the Illinois Department of Financial and Professional Regulation proposed...

United StatesFinance and Banking
Holly Spencer Bunting
Holly Spencer Bunting
Grace Kim
Grace Kim
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Illinois continues to move forward in regulating "shared appreciation agreements." On August 15, 2025, the Illinois Department of Financial and Professional Regulation proposed regulations implementing the Residential Mortgage License Act of 1987 ("RMLA") to govern "shared appreciation agreements" (the "Proposed Regulations").1 The term "shared appreciation agreements" is generally interpreted to include products commonly known as "home equity contracts," "home equity investments," or "home equity agreements." The Proposed Regulations provide originators of these products with a roadmap for compliance with the RMLA. Below is a summary of certain key provisions in the Proposed Regulations.

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