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The FAQ answers are provided solely as APLD guidance and are not to be viewed as legal written interpretations of the Illinois Department of Financial and Professional Regulation.

closed answer Question: Who is IDFPR working with to protect consumers?

IDFPR is working with the Governor, legislators, consumer groups and the lending industry to develop and implement programs that protect consumers while ensuring the continuing vitality of the mortgage industry.
closed answer Question: What are the goals of the Anti-Predatory Lending Database Program?

The APLD is designed to increase borrowers’ knowledge about loans they are considering and to reduce the number of foreclosures resulting from inappropriate loans. The database will collect information about mortgage loans in Cook County and determine whether or not each particular borrower needs to attend housing counseling provided by a HUD-certified/approved housing counselor.
closed answer Question: What if the counselor advises against taking a particular loan?

The decision whether to proceed with a loan is entirely that of the borrower who may accept or reject the advice of the counselor. The APLD is designed to provide borrowers with the knowledge necessary to make informed financial decisions and thereby protect themselves, their families, and their homes.
closed answer Question: How long will a counseling session be?

The law does not specify the length of counseling sessions, but sets forth the items that must be covered to ensure that the counseling will be meaningful to the borrower. An average session may last 1 - 2 hours.
closed answer Question: Does providing personal confidential data to the State create a security risk?

Mortgage brokers typically share borrowers’ personal financial information with various lenders through secure electronic systems in order to obtain the best possible mortgage for the borrower. IDFPR will include such security features in the APLD and take all necessary action to protect confidential information. Only specifically designated and trained agency personnel will be granted access to view and evaluate this information.
closed answer Question: How can I verify if an entity is really exempt?

Banks and Credit Unions may be verified through The National Information Center. Go to and click on "National Info Center". Licensees of IDFPR can be verified through the IDFPR website at Click on "Banking", and then click on Banking License Lookup".
closed answer Question: Does an exempt entity need to register with the database?

Generally, no. However, there is one exception. If the entity plans to close any of its loans in-house, it must obtain a password as a closer in order to generate the required exempt certificate.
closed answer Question: Must all loans in which the points and fees exceed 5% be classified as High Cost loans pursuant to the Illinois High Risk Home Loan Act?

No. The Illinois High Risk Home Loan Act (HRHLA), 815 ILCS 137, is a separate and distinct statute from the APLD with its own requirements. The APLD points and fees calculation is used solely as a standard for counseling. To determine whether a loan is High Cost, refer to the HRHLA and follow the procedures therein.
closed answer Question: What property is eligible for Government Property exemption?

Pursuant to the requirements of the Illinois Anti-Predatory Lending Database Program ("APLD") mortgage loans secured by government property are classified as exempt transactions. However, there appears to be confusion as to the meaning of "Government Property". Government property would be a facility which contains government offices or from which a government function takes place. Examples include, but are not limited to, the Thompson Center, Daley Center, Secretary of State Driver's License facilities, City Hall, court houses, police and fire stations, federal buildings. All levels of buildings from local to federal are included. Residential properties including HUD homes are NOT classified as government property as no government function takes place there. Mortgage loans secured by such properties are subject to all the data entry, counseling, and closing agent requirements set forth by the APLD. Such transactions may be exempt for various reasons such as having been originated by a bank or being purchased by an investor, but the "Government Property" exemption does not apply.
closed answer Question: How are points and fees calculated by the broker/originator? How are points and fees calculated by the closing agent?

Numerator (Dividend): 800 fields from HUD-1 containing prepaid finance charges paid to lender, mortgage broker, and affiliates + supplemental fields corresponding to HUD-1 Section 1300 including all such fees POC + yield spread premium paid to mortgage broker (Include in Line 801) + the maximum prepayment fees and penalties that may be charged or collected under the terms of the credit transaction + all prepayment fees or penalties that are incurred by the consumer if the loan refinances a previous loan made or currently held by the same creditor or an affiliate of the creditor + premiums or other charges payable at or before closing or financed directly or indirectly into the loan for any credit life, credit disability, credit unemployment, credit property, other accident, loss of income, life or health insurance or payments directly or indirectly for any debt cancellation or suspension agreement or contract + real estate related fees paid to an affiliate or for which the creditor receives compensation + certain bona fide discount points.

Denominator (Divisor): Principal amount of new loan from line 202 minus 800 fields containing prepaid finance charges paid to lender, mortgage broker, and affiliates + supplemental fields corresponding to HUD-1 Section 1300 including all such fees POC.

Quotient: Numerator divided by Denominator = Points and fees %

Notes: 1. Since closing credits may be taken into account, the broker/originator should include in the calculation only those fees actually being paid by the borrower from borrowers’ funds. YSP is always included in the calculation. FHA upfront MIP and VA funding fees are not included in the calculation 2. Fees paid directly by the borrower to third parties not affiliated with the broker or lender are not included unless (i) The broker or lender requires use of the third party as a condition of or an incident to the loan, even if the consumer can choose the third party; or (ii) the broker or lender retains a portion of the third-party charge, to the extent of the portion retained. 12 CFR 226.4(a)(1). 3. Insurance premiums or debt cancellation or suspension fees calculated and paid in full on a monthly basis shall not be considered financed by the creditor and are not included in the calculation. 4. Real estate related fees include title fees, survey, document prep, notary, credit reports, appraisals, and home inspections. 5. Bona fide discount points over 2 if interest rate without any discount does not exceed APOR by more than 1 percentage point; or, bona fide discount points over 1 if interest rate without any discount does not exceed APOR by more than 2 points. APOR = Average Prime Offer Rate.

Effective 1/10/2014

closed answer Question: How much time do I have to enter my loan into the database?

All loans must be entered within a ten business day window after its origination.
closed answer Question: What names must appear on the APLD Certificates?

Names on the certificates must include the Lender and at least one of the borrowers.
closed answer Question: Must I input income when entering an FHA Streamline Loan?

FHA Streamline Refinances are not exempt under Illinois law from the requirement to enter borrower income information. It is not acceptable to enter a nominal amount such as $1.00 as borrower income. You must enter the borrowers actual income (as provided by the borrower or estimated from the borrowers information).
closed answer Question: Who is responsible for the cost of counseling?

The mortgage broker is responsible for the counseling cost, which cannot exceed $300.00
closed answer Question: Who are the HUD-certified/approved counseling agencies currently participating in the program?

Housing Counselors:
Agora Community Services Corporation, NFP1831 E 79TH STREET
Chicago, IL 60649
Bethel New Life, Inc.310 N Pulaski Rd
Chicago, IL 60624
Brighton Park Neighborhood Council4477 South Archer Ave
Chicago, IL 60632
Catholic Charities of the Archdiocese of Chicago, Lake County Services671 S Lewis Ave
Waukegan, IL 60085
CEDA (Near South)/ CEDA Center for Community Action53 E 154th St
Harvey, IL 60426
CEDA Near West6141 West Roosevelt Road
Cicero, IL 60804
CEDA of Cook County Inc567 West Lake Street, Ste 1900
Community Service Council of Northern Will County440 Quadrangle Dr, Suite C
Bolingbrook, IL 60440
Consumer Credit Counseling Service of Northern Illinois, Inc 400 Russel Court , P.O. Box 885
Woodstock, IL 60098
Consumer Credit Counseling Service of Northern Illinois, Inc.400 Russel Court P.O. Box 885
Woodstock, IL 60098
Consumer Credit Counseling Service/A Program of Family Counseling70 South River Street, Suite 1
Aurora, IL 60506
Consumer Credit Counseling Services (CCCS) of Elgin1900 Hassell Road
Hoffman Estates, IL 60194
Consumer Credit Counseling Services (CCCS) of Elgin22 S. Spring Street
Elgin, IL 60120
Consumer Credit Counseling Services (CCCS), a Division of Money Management International416 Main St, Suite 920
Peoria, IL 61602
Du Page Homeownership Center, Inc.1600 E Roosevelt Road
Wheaton, IL 60187
Embarras River Basin Agency, Inc.400 West Pleasant Street
Greenup, IL 62428
Greater Southwest Development Corporation6155 S. Pulaski
Chicago, IL 60629
Housing Opportunity Development Corporation2001 Waukegan Rd
Techny, IL 60082
Institute For Consumer Credit Education16335 S Harlem Ave, Suite 400
Tinley Park, IL 60477
Joseph Corporation of Illinois, Inc.32 South Broadway Avenue
Aurora, IL 60507
Kingdom Community, Inc.5151 West Madison Street
Chicago, IL 60644
Lakeside Community Development Corporation6636 N Clark St.
Chicago, IL 60626
Latin United Community Housing Association3541 W North Ave
Chicago, IL 60647
METEC Housing Counseling Resource Center2605 W Krause
Peoria, IL 61605
Mortgage Education Foundation7808 W. College Drive, Suite LL 3
Palos Heights, IL 60463
Neighborhood Housing Services Of Chicago (NHS)1279 N Milwaukee
Chicago, IL 60622
NHS of Chicago - Auburn Gresham - Englewood449 W. 79th St.
Chicago, IL 60620
NHS of Chicago – Back of the Yards/Garfield Boulevard1658 W. 47th St.
Chicago, IL 60609
NHS of Chicago – Chicago Lawn/ Gage Park2609 W. 63rd St.
Chicago, IL 60629
NHS of Chicago – South Chicago9108 S. Brandon
Chicago, IL 60617
NHS of the Fox Valley163 E Chicago St
Elgin, IL 60637
NID-HCA Simmons6459 S Cottage Grove
Chicago, IL 60637
NID-HCA Webber8543 S Stony Island Ave
Chicago, IL 60617
North Side Community Federal Credit Union1011 W Lawrence Ave
Chicago, IL 60640
North West Housing Partnership1701 E Woodfield Road, Suite 203
Schaumburg, IL 60173
Northside Community Development Corporation1530 W. Morse Avenue
Chicago, IL 60626
Northwest Side Housing Center5007 W Addison
Chicago, IL 60641
Oak Park Regional Housing Center1041 South Boulevard
Oak Park, IL 60302
OPEN COMMUNITIES614 Lincoln Avenue
Winnetka, IL 60093
Partners in Charity, Inc.86 N. Williams Street
Crystal Lake, IL 60014
Partners In Community Building, Inc.3424 South State Street , Suite 1A8-1
Chicago , IL 60616
Regional Fair Housing Center (LCOC)9730 S Western Ave, Suite 502
Evergreen Park, IL 60805
Smart Money Housing1450 East American Lane, Zurich Towers, Suite 1400
Schaumburg, IL 60173
Smart Money HousingOne Westbrook Corporate Center, Suite 300
Westchester, IL 60154
Smart Money Housing aka Smart Women Smart Money3510 W Franklin Blvd
Chicago , IL 60624
South Side Community Federal Credit Union5401 S Wentworth Ave, Suite 25
Chicago, IL 60609
South Suburban Housing Center18220 Harwood Avenue, Suite 1
Homewood, IL 60430
Southeast CEDA3518 W 139th St
Robbins, IL 60472
Spanish Coalition for Housing1915 S. Blue Island
Chicago, IL 60608
Spanish Coalition For Housing1922 N PULASKI
Spanish Coalition for Housing4035 W. North
Chicago, IL 60639
Spanish Coalition for Housing9010 S. Commercial Ave
Chicago, IL 60617
The Chicago Urban League4510 South Michigan Avenue
Chicago, IL 60653
The Resurrection Project1818 S Paulina
Chicago, IL 60608
Will County Center for Community Concerns2455 Glenwood Avenue
Joliet, IL 60435
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