- Official section
- Illinois II.L: CMA and BPO Requirements
- Broker weight
- Part of 40% of the Illinois state portion
- Expected scored items
- The current PSI broker outline assigns 16 of 40 state items to this area
Illinois License Act topic guide
Illinois CMA and BPO requirements
A CMA or BPO can inform a price decision without crossing into appraisal practice. The exam asks you to identify the product, user, purpose, written contents, mortgage boundary, preparer's interest, license identity, and not-an-appraisal statement as one connected compliance decision.
Last updated: August 1, 2026
What does current Illinois authority require?
Short answer: An Illinois broker or managing broker may prepare a written CMA or BPO for buyers, sellers, lessors, lessees, specified due-diligence users, lienholders, and other third parties, but not as the primary market-value basis for a financial institution's mortgage-loan origination secured by the property. The report must state purpose, describe the real estate interest and methodology, list assumptions and limiting conditions, disclose the broker's existing or contemplated interest, provide the preparer's real estate license identity and signature, and state that the product is not an appraisal.
The broker outline effective June 24, 2026 expressly tests CMA and BPO requirements. This guide applies 225 ILCS 454/10-45, the current Section 1-10 definitions, and Rule 1450.790 as checked on August 1, 2026. The rule was amended effective July 7, 2025. Lenders, courts, investors, government programs, and clients may impose stricter assignment requirements, and the Illinois Real Estate Appraiser Licensing Act controls work represented or required as appraisal practice.
Where is this tested on the Illinois outline?
- Topic
- Illinois BPO definition
- What to know
- Broker price opinion, estimate, analysis, probable selling price, particular real estate interest, condition, market, neighborhood, comparable sales, varying detail, compensation, ordinary brokerage, sale commission, rental compensation, and not an appraisal
- Best exam move
- Identify the probable-selling-price product and do not turn detail, inspection, or a price conclusion into an appraisal label.
- Topic
- Illinois CMA definition
- What to know
- Comparative market analysis, analysis, opinion, pricing, marketing, financial aspects, specified real estate interest, comparative market data, broker expertise, other factors, listing consultation, buyer strategy, compensation, and ordinary course
- Best exam move
- Use the product's purpose and statutory description rather than assuming every comparable-sales grid has the same legal classification.
- Topic
- Qualified preparer
- What to know
- Licensed broker, licensed managing broker, active license, sponsorship, supervision, residential leasing agent, unlicensed assistant, appraiser credential, real estate license number, signature, developer, and preparer
- Best exam move
- Require broker or managing-broker authority and use the real estate credential for a BPO or CMA, even when the preparer also holds an appraiser license.
- Topic
- Buyers, sellers, lessors, and lessees
- What to know
- Existing buyer, potential buyer, existing seller, potential seller, real estate interest, lessor, lessee, listing decision, offering price, purchase price, option, lease rate, acquisition, disposition, client, and consumer
- Best exam move
- Match the product to a legitimate pricing, marketing, lease, or acquisition decision for the intended user.
- Topic
- Third-party and due-diligence uses
- What to know
- Third party, decision, due diligence, potential listing, offering, sale, option, lease, acquisition price, lienholder, servicer, investor, relocation, portfolio review, estate planning, litigation, tax matter, client instruction, and permitted purpose
- Best exam move
- A third-party request is not automatically prohibited, but the exact purpose determines whether Section 10-45 allows the assignment.
- Topic
- Mortgage-origination boundary
- What to know
- Financial institution, mortgage loan, origination, secured by real estate, primary basis, market value, lienholder, underwriting, collateral, appraisal requirement, evaluation, federal rule, loan renewal, workout, portfolio, and prohibited use
- Best exam move
- Reject the BPO or CMA when it would be the primary basis for the secured property's market value in financial-institution mortgage origination.
- Topic
- Written format and intended purpose
- What to know
- Paper, electronic writing, report, intended purpose, intended user, assignment request, effective date, scope, version, delivery, records, title, clarity, and use limitation
- Best exam move
- State the specific decision the analysis supports; a generic for any purpose statement weakens both compliance and reliability.
- Topic
- Real estate interest description
- What to know
- Property address, legal interest, fee simple, leasehold, partial interest, unit, parcel, rights analyzed, ownership, option interest, subject identification, relevant characteristics, and property condition
- Best exam move
- Describe the actual interest being priced, not only a street address that leaves the property right ambiguous.
- Topic
- Methodology and market support
- What to know
- Methodology, comparable selection, listing, pending sale, closed sale, verification, date range, geography, property type, adjustment, reconciliation, market trend, condition observation, source, data limitation, and probable price conclusion
- Best exam move
- Show how evidence leads to the conclusion; a list of comps without method or reconciliation does not explain the opinion.
- Topic
- Assumptions and limiting conditions
- What to know
- Assumption, limiting condition, no inspection, exterior inspection, interior inspection, data accuracy, title, zoning, legal use, environmental condition, repair estimate, extraordinary fact, access, reliance, update, effective date, and uncertainty
- Best exam move
- Disclose what was assumed and what the broker did not verify so the user does not mistake an input limitation for a confirmed fact.
- Topic
- Broker interest and identity
- What to know
- Existing interest, contemplated interest, purchase plan, ownership, option, commission, listing opportunity, conflict, disclosure, name, license number, signature, real estate credential, initial page, and dual-licensed appraiser
- Best exam move
- Disclose the property interest and identify the actual developer of the analysis under the broker credential.
- Topic
- Not-an-appraisal statement and discipline
- What to know
- Substantially prescribed statement, broker price opinion, comparative market analysis, not an appraisal, market value, licensed broker, licensed managing broker, not acting as State certified appraiser, false statement, misleading statement, inadequate preparation, improper preparation, Section 20-20, and discipline
- Best exam move
- Include the statutory statement, but also make the underlying work accurate and adequate because a disclaimer does not cure poor preparation.
The PRICEPATH method for Illinois CMA and BPO questions
- Pin down the product. Decide whether the assignment is a CMA, BPO, appraisal, AVM output, informal brokerage discussion, or another analysis.
- Read the intended user. Identify buyer, seller, lessor, lessee, decision-making third party, lienholder, financial institution, or another recipient.
- Identify the exact purpose. State the listing, offering, sale, option, lease, acquisition, portfolio, workout, or other decision the opinion supports.
- Check the mortgage boundary. If the product is the primary market-value basis for financial-institution mortgage origination secured by the property, stop and use the required valuation route.
- Explain the interest analyzed. Describe the parcel and the legal or economic interest, not only the address.
- Present the methodology. Identify data, comparable selection, verification, adjustments or comparison logic, market conditions, and reconciliation.
- Attach assumptions and limits. Make inspection scope, unverified facts, data constraints, and use limits visible.
- Tell the preparer's interest. Disclose an existing or contemplated stake in the subject real estate.
- Authenticate and label. Use the developing broker's name, real estate license number, signature, and substantially prescribed not-an-appraisal statement.
- Required element
- Intended purpose
- What it answers
- Why the report exists
- Exam failure to avoid
- Generic use with no decision
- Required element
- Real estate interest
- What it answers
- What property right is analyzed
- Exam failure to avoid
- Address only when interest differs
- Required element
- Methodology
- What it answers
- How the conclusion was developed
- Exam failure to avoid
- Unexplained price number
- Required element
- Assumptions and limits
- What it answers
- What was assumed or not verified
- Exam failure to avoid
- Silent inspection or data gap
- Required element
- Existing or contemplated interest
- What it answers
- Whether preparer has a stake
- Exam failure to avoid
- Hidden acquisition plan
- Required element
- Name and real estate license number
- What it answers
- Who developed the work
- Exam failure to avoid
- Appraiser number on a BPO
- Required element
- Signature
- What it answers
- Who authenticates the report
- Exam failure to avoid
- Anonymous template output
- Required element
- Not-an-appraisal statement
- What it answers
- Which product was delivered
- Exam failure to avoid
- Implied certified appraisal
- Required element
- Optional appropriate items
- What it answers
- What else supports intended use
- Exam failure to avoid
- Treating minimum as maximum
Which Illinois distinctions matter most?
- Terms
- CMA vs. BPO
- Difference
- A CMA is defined around pricing, marketing, or financial analysis and often supports brokerage strategy. A BPO is defined as an estimate or analysis of probable selling price. Section 10-45 applies the same written-content and use requirements to both.
- Question cue
- Broader market strategy analysis versus probable selling-price opinion.
- Terms
- CMA or BPO vs. appraisal
- Difference
- A CMA or BPO is a brokerage product prepared under the Real Estate License Act. An appraisal is developed and communicated under appraisal licensing law and applicable standards.
- Question cue
- Broker pricing product versus regulated value opinion.
- Terms
- Probable selling price vs. market value
- Difference
- Probable selling price anticipates a likely transaction outcome in the stated context. Market value is a defined value concept tied to specified assumptions, rights, date, and intended use.
- Question cue
- Likely sale result versus defined value premise.
- Terms
- Ordinary listing analysis vs. statutory compensated BPO
- Difference
- The definitions exclude ordinary brokerage activity from BPO or CMA classification when no separate compensation is paid other than compensation based on sale or rental. A separately commissioned pricing product receives the formal statutory treatment.
- Question cue
- Incidental brokerage advice versus compensated standalone opinion.
- Terms
- Permitted lienholder use vs. prohibited origination use
- Difference
- A lienholder or third party may request the product for a permitted purpose. It may not be the primary market-value basis for a financial institution's mortgage-loan origination secured by the property.
- Question cue
- Portfolio or due diligence versus primary origination valuation.
- Terms
- Methodology vs. assumptions
- Difference
- Methodology explains how the broker developed the opinion. Assumptions and limiting conditions identify facts taken as true and constraints on investigation or use.
- Question cue
- Analytical process versus boundaries on that process.
- Terms
- Property interest disclosure vs. compensation disclosure
- Difference
- Section 10-45 specifically requires disclosure of an existing or contemplated interest in the subject real estate. Compensation follows separate brokerage and source-disclosure rules and does not replace the property-interest disclosure.
- Question cue
- Stake in the real estate versus payment for services.
- Terms
- Broker credential vs. appraiser credential
- Difference
- When a dual licensee prepares a BPO or CMA, Rule 1450.790 requires the broker or managing-broker name and license number on the initial page, not the appraiser license number.
- Question cue
- Credential matching the product actually delivered.
How does the Illinois rule apply?
A seller listing CMA
Scenario: A broker prepares an electronic analysis for a potential seller comparing six recent sales and three competing listings to recommend a listing range. The report states the purpose, property interest, method, data limits, broker identity, signature, and not-an-appraisal statement.
- A potential seller is an expressly authorized recipient.
- Listing and offering price are permitted purposes.
- The written report contains the core Section 10-45 elements and is presented as a CMA rather than an appraisal.
Answer: The product fits a permitted Illinois CMA, assuming the broker's interest disclosure is also complete and the analysis is accurate and adequately prepared.
A lender wants to avoid an appraisal
Scenario: A financial institution asks a broker for a BPO that will be the primary basis for the market value used to originate a new mortgage secured by the subject home. The lender says a bold not-an-appraisal disclaimer will make the assignment lawful.
- The request is tied to mortgage-loan origination by a financial institution.
- The BPO would be the primary basis for determining the secured property's market value.
- Section 10-45 excludes that use, and a disclaimer cannot alter the actual purpose.
Answer: The broker should not accept the assignment as a Section 10-45 BPO for that primary origination purpose. The institution must use the valuation product the law and program require.
A hidden purchase plan
Scenario: A managing broker prepares a low BPO for an estate representative while quietly planning to buy the property through an LLC. The report identifies the method and data but says the broker has no interest because the LLC has not yet made an offer.
- Section 10-45 reaches both existing and contemplated interests in the subject real estate.
- A planned acquisition through an entity is still a contemplated interest that the user should see.
- The false no-interest statement also creates misleading-statement and inadequate-preparation discipline risk.
Answer: The broker must disclose the contemplated interest. Waiting for a formal offer does not erase the present acquisition plan.
One professional holds two licenses
Scenario: A person licensed as both an Illinois managing broker and a certified appraiser prepares a BPO for a permitted portfolio review. The initial page lists only the appraiser credential and uses an appraisal certification block.
- The assignment is being delivered as a BPO under brokerage law, not as an appraisal.
- Rule 1450.790 requires the managing-broker or broker name and license number on the initial page, not the appraiser license number.
- Appraisal certification language can also confuse the nature of the product.
Answer: Identify and sign under the real estate managing-broker credential, include the required BPO statement, and keep the product classification clear.
Where do candidates misread the Illinois rule?
- Trap
- A CMA and appraisal are interchangeable if they use the same comparables.
- Correction
- The products operate under different licensing frameworks, purposes, representations, and required statements.
- Trap
- A BPO may be used for every lender purpose.
- Correction
- It may not serve as the primary market-value basis for financial-institution mortgage origination secured by the property.
- Trap
- An oral price opinion satisfies Section 10-45.
- Correction
- A qualifying BPO or CMA must be written on paper or electronically and include the statutory elements.
- Trap
- The property address alone always describes the interest analyzed.
- Correction
- The statute requires a brief description of the real estate interest, which can matter when rights, units, or partial interests differ.
- Trap
- A list of comparable sales is a complete methodology description.
- Correction
- The report should explain how the evidence was selected and used to develop the conclusion.
- Trap
- Only an existing ownership interest must be disclosed.
- Correction
- Section 10-45 also requires disclosure of a contemplated interest in the subject real estate.
- Trap
- A dual licensee should use the appraiser number to make the BPO more credible.
- Correction
- Rule 1450.790 requires the real estate broker or managing-broker identity and license number on the initial page.
- Trap
- The not-an-appraisal statement cures misleading or inadequate work.
- Correction
- The report can still produce discipline for false statements or inadequate or improper preparation.
- Trap
- Any third-party request is prohibited.
- Correction
- Section 10-45 expressly permits specified third-party decision and due-diligence uses, subject to the purpose limitation.
- Trap
- A residential leasing agent may sign a CMA because leases are included.
- Correction
- Section 10-45 authorizes brokers and managing brokers, not residential leasing agents, to prepare the product.
Can you apply the rule to a fresh scenario?
These questions are original study items aligned to the published outline. They are not copied, recalled, or predicted PSI questions.
1. Which use is prohibited for an Illinois BPO under Section 10-45?
- Helping a potential seller consider a listing price
- Supporting a potential lessee's lease decision
- Serving as the primary market-value basis for a financial institution's secured mortgage origination
- Helping a third party perform permitted acquisition-price due diligence
Show answer and explanation
Answer: C
Section 10-45 draws a specific line at primary market-value use for financial-institution mortgage origination secured by the real estate.
2. Which item must appear in the written Illinois CMA or BPO?
- A guarantee that the property will sell at the stated price
- A description of the methodology used
- An appraiser certification in every case
- A lender underwriting approval
Show answer and explanation
Answer: B
The statutory checklist includes a brief methodology description, not a guaranteed result or appraisal certification.
3. A broker hopes to buy the subject property but has made no offer. What must the BPO disclose?
- Nothing until a contract is signed
- Only the broker's commission split
- The contemplated interest in the subject real estate
- The seller's confidential motivation only
Show answer and explanation
Answer: C
The interest disclosure covers existing and contemplated interests, so a present acquisition plan is relevant before an offer exists.
4. Which credential should a dual-licensed broker-appraiser place on the initial page of a BPO?
- Only the appraiser license number
- The real estate broker or managing-broker name and license number
- No license number
- An unlicensed assistant's name
Show answer and explanation
Answer: B
Rule 1450.790 requires identity under the brokerage credential because the product is a BPO or CMA, not an appraisal.
5. A CMA contains the required disclaimer but invents two comparable sales. Which answer is best?
- The disclaimer prevents discipline
- The false information can support discipline despite the disclaimer
- Comparable data never matters in a CMA
- Only an appraiser may verify sales
Show answer and explanation
Answer: B
Rule 1450.790 permits discipline for false, untruthful, or misleading statements and inadequate or improper preparation.
How should you review this Illinois topic?
- Session
- 1. Separate the products
- Focus
- CMA, BPO, appraisal, probable selling price, market value, pricing, marketing, financial analysis, ordinary brokerage advice, and separate compensation
- Proof you are ready
- Classify twenty requested products by purpose, representation, and governing credential.
- Session
- 2. Map users and purposes
- Focus
- Buyer, seller, lessor, lessee, third party, due diligence, listing, offering, sale, option, lease, acquisition, lienholder, financial institution, and mortgage origination
- Proof you are ready
- Decide permitted or prohibited use in fifteen recipient-purpose combinations.
- Session
- 3. Memorize the report checklist
- Focus
- Purpose, interest, methodology, assumptions, limiting conditions, preparer interest, name, license number, signature, disclaimer, and optional supporting items
- Proof you are ready
- Reconstruct all required Section 10-45 elements from memory twice.
- Session
- 4. Practice credible methodology
- Focus
- Data source, verification, comparable selection, condition, market area, time, adjustment, competing listing, pending sale, closed sale, trend, and reconciliation
- Proof you are ready
- Explain a supported probable-price conclusion without appraisal terminology.
- Session
- 5. Audit conflicts and labels
- Focus
- Existing interest, contemplated interest, entity purchase, license identity, dual licensure, initial page, real estate number, signature, not-an-appraisal statement, and discipline
- Proof you are ready
- Correct ten reports with hidden interests, wrong credentials, or misleading product labels.
- Session
- 6. Apply PRICEPATH
- Focus
- Product, user, purpose, mortgage boundary, interest, method, assumptions, conflict, identity, label, and adequacy
- Proof you are ready
- Score at least 90% on fresh Illinois CMA and BPO questions.
Do not count recognition as mastery. Close the notes and explain the rule, apply it to a new fact pattern, and identify why each distractor fails.
Practice the Illinois rule in context
From concept to decision
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Questions students ask about Illinois CMA and BPO Requirements
What is a broker price opinion in Illinois?
The License Act defines a broker price opinion as an estimate or analysis of the probable selling price of a particular interest in real estate. It may include varying detail about condition, market, neighborhood, and comparable sales. It is not an appraisal under the Illinois Real Estate Appraiser Licensing Act.
What is a comparative market analysis in Illinois?
A comparative market analysis is an analysis or opinion about pricing, marketing, or financial aspects of a specified real estate interest. It may use comparative market data, the broker's or managing broker's expertise, and other factors considered appropriate. A CMA does not become an appraisal merely because it is detailed.
Who may prepare an Illinois BPO or CMA?
Section 10-45 authorizes a licensed real estate broker or managing broker to prepare or provide one for the listed users and purposes. A residential leasing agent or unlicensed assistant does not receive that authority. Sponsorship, supervision, compensation, and recordkeeping rules also remain relevant.
For whom may an Illinois broker prepare a BPO or CMA?
Authorized recipients include an existing or potential buyer or seller, an existing or potential lessor or lessee, a third party making decisions or performing due diligence related to a potential listing, offering, sale, option, lease, or acquisition price, and a lienholder or other third party for a permitted purpose.
Can an Illinois BPO or CMA be used to originate a mortgage loan?
It cannot serve as the primary basis for determining market value for mortgage-loan origination by a financial institution when the loan is secured by that real estate. Section 10-45 permits lienholder and third-party uses only outside that prohibited primary-basis purpose. If an appraisal is required, a BPO or CMA is not a substitute.
Must an Illinois BPO or CMA be written?
Yes. A qualifying BPO or CMA under Section 10-45 must be in writing, either on paper or electronically. It must state its intended purpose, identify the real estate interest, describe methodology, disclose assumptions and limiting conditions, disclose the preparer's existing or contemplated interest, identify and authenticate the broker, and include the statutory not-an-appraisal statement in substantially the prescribed form.
What license number belongs on an Illinois CMA or BPO?
The report includes the name and real estate license number of the broker or managing broker who developed it. If that person also holds an appraiser license, Rule 1450.790 requires the broker or managing-broker name and license number on the initial page, not the appraiser license number.
Must an Illinois CMA or BPO disclose the broker's interest in the property?
Yes. The written report must disclose any existing or contemplated interest of the broker or managing broker in the real estate interest that is the subject of the analysis. This makes a planned acquisition or other relevant interest visible to the user.
What happens if an Illinois CMA or BPO does not comply with Section 10-45?
Rule 1450.790 makes the broker or managing broker subject to discipline for false, untruthful, or misleading statements, inadequate or improper preparation, or another violation covered by Section 20-20. A disclaimer alone does not excuse weak or deceptive analysis.
Are these official Illinois broker exam questions?
No. They are original study questions aligned to CMA and BPO requirements in Section II.L of the Illinois outline effective June 24, 2026. Section 10-45, Rule 1450.790, appraisal definitions, and IDFPR curriculum were checked through August 1, 2026.
Primary sources
- PSI Illinois Candidate Information Booklet dated June 24, 2026
- 225 ILCS 454/10-45, authorized CMA and BPO uses and report content
- 225 ILCS 454/1-10, BPO, CMA, broker, and compensation definitions
- 68 Ill. Adm. Code 1450.790, credential identity and discipline
- 225 ILCS 458/1-10, Illinois appraisal definitions
- 225 ILCS 454/20-20, grounds for real estate discipline
- IDFPR 6-hour Core CE curriculum, CMA, BPO, and appraisal topics
The current official outline controls the tested scope. Statutes, regulations, and official agency materials control when a general study rule and a jurisdiction-specific rule differ.
Editorial status
Checked against primary sources
The Pass Illinois editorial team last checked this guide on August 1, 2026. Every practice question is an original study item, and the source links above let you verify the rules that support the lesson.