Illinois License Act topic guide
Illinois CMA and BPO requirements
A free listing-price discussion and a separately commissioned broker price opinion are not automatically the same statutory product. Before checking the report, check the assignment, compensation and intended use. A polished template cannot fix a prohibited purpose or invented evidence.
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The short answer
For a covered Illinois CMA or BPO, section 10-45 authorizes brokers and managing brokers for specified users and purposes and requires a written report with seven listed subjects, including the not-an-appraisal statement. First apply the ordinary-course brokerage exclusion in both product definitions. Then check the mortgage-origination use limit, the developer’s identity and interest, and whether the analysis is accurate and adequately prepared. A CMA or BPO does not replace an appraisal when an appraisal is required.
Reviewed October 26, 2026. PSI lists CMA/BPO requirements in Illinois II.L. The whole Illinois Real Estate License Act domain has 16 of the 40 scored state broker questions; that is not a quota for this topic. The examples apply the identified Illinois statutes and rule 1450.790, whose current amendment note is July 7, 2025. These are original teaching questions, not PSI items, approved report forms or a decision about an actual lender assignment.
Check coverage, use and contents in that order
- Name the product and apply the definition. A statutory BPO estimates or analyzes probable selling price for a particular real estate interest. A statutory CMA addresses pricing, marketing or financial aspects of a specified interest, using comparative data, expertise or other appropriate factors. Both definitions exclude ordinary-course brokerage activity when no compensation is paid other than compensation based on the sale or rental of real estate. This is not a blanket exemption for every free opinion. Compensation is not limited to cash. Valuable consideration such as services or a gift certificate supplied in exchange for the analysis can matter to that exclusion.
- Check who is doing the work. Section 10-45 authorizes a real estate broker or managing broker. A residential leasing agent does not gain that authority merely because a lease is involved, and an unlicensed assistant cannot independently develop and deliver the opinion under someone else’s credential. Sponsorship and supervision requirements still apply to licensed work.
- Read the actual user and purpose. The statute includes existing or potential buyers, sellers, lessors and lessees; specified third-party decisions or due diligence about a listing, offering, sale, option, lease or acquisition price; and the qualified lienholder or other third-party category. Do not decide permission from the recipient’s job title alone.
- Apply the exact mortgage limit. A BPO or CMA cannot be the primary basis for determining the market value of the subject real estate for a financial institution’s mortgage-loan origination secured by it. A disclaimer, small fee, lower loan amount or portfolio label does not change that actual use. This is not a ban on every bank request, and an otherwise permitted broker product is not automatically an acceptable appraisal or evaluation for a particular loan program.
- For a covered report, complete the section 10-45(b) subjects in paper or electronic writing. Identify purpose; briefly describe the real estate interest and methodology; disclose assumptions or limiting conditions and any existing or contemplated preparer interest; include the developing broker’s or managing broker’s name, license number and signature; and use the substantially prescribed statement. Other appropriate items may be added, but do not replace the required subjects.
- Make the analysis understandable. Describe the rights being analyzed rather than leaving a leasehold or partial interest ambiguous. Explain how the data support the conclusion. Identify relevant investigation and data limitations, such as an exterior-only observation or unverified interior condition. A limitation does not permit inventing a sale, claiming an inspection never performed or hiding a known contradictory fact.
- Keep the brokerage credential clear. The statute requires the actual developer’s name, license number and signature for the covered report. Rule 1450.790(a) specifically requires a person licensed both as broker or managing broker and as appraiser to use the brokerage name and license number, not the appraiser number, on the initial page. That sentence is not a substitute for identifying and authenticating every covered report correctly.
- Check interests, confidentiality and payment separately. A contemplated purchase of the subject property must not be hidden merely because no offer has been made. Required property-interest disclosure does not authorize revealing a client’s confidential negotiating information. For ordinary current sponsored work with no applicable exception, compensation is received through the sponsoring broker. Neither a payment arrangement nor a disclaimer cures deficient or misleading preparation.
| Provision | Report subject | What to check |
|---|---|---|
| (1) | Intended purpose | State the decision the analysis supports |
| (2) | Interest in real estate | Identify the actual interest analyzed |
| (3) | Methodology | Briefly explain how the opinion was developed |
| (4) | Assumptions or limiting conditions | Make relevant limits visible |
| (5) | Existing or contemplated preparer interest | Disclose the actual or planned stake |
| (6) | Developer identity and authentication | Name, real estate license number and signature |
| (7) | Substantially prescribed statement | Identify the broker product and distinguish appraisal |
| (8) | Other appropriate items | Additional material does not replace subjects (1)-(7) |
The distinctions that matter
| Distinction | How it works | What to notice |
|---|---|---|
| Everyday CMA language and statutory coverage | People may call ordinary listing-price comparisons a CMA. The Act’s definitions contain the ordinary-course and compensation exclusion for both CMA and BPO. | Classify the facts before demanding or dismissing the statutory checklist. |
| CMA and BPO | A CMA has the broader pricing, marketing or financial-analysis definition. A BPO focuses on probable selling price. Covered products share the section 10-45 requirements. | Different definitions, shared written-report and use rules. |
| Broker product and appraisal | Shared comparable data, a detailed grid or an interior visit does not make the products interchangeable. Appraisal practice has its own authority and requirements. | A label cannot confer an appraiser credential. |
| Permitted user and permitted assignment | A lienholder is an identified recipient category, but the actual use can still fall within the prohibited primary origination purpose. | Who asks and why they ask are separate facts. |
| Method and limitation | Method explains development. A limitation identifies a constraint or assumption. An anonymous number with an unexplained limitation is not a complete analytical method. | No interior access must not become interior condition verified. |
| Developer and template publisher | The statutory identity belongs to the broker or managing broker who developed the report. A vendor logo or supervisor’s number alone does not identify that person. | A template is a tool, not the named developer. |
| Report identity and dual-license initial page | Section 10-45(b)(6) governs covered-report identity. Rule 790(a)’s particular initial-page instruction concerns dual licensees. | Do not turn one rule’s stated scope into a different blanket rule. |
| Required interest disclosure and unrestricted sharing | An existing or contemplated real estate interest must be disclosed in the covered report. Protected client information remains subject to its own safeguards. | Disclosing a purchase plan does not authorize disclosing a confidential bottom line. |
Work through the facts
The ordinary listing consultation
A properly licensed broker compares prices while seeking an ordinary listing. The facts stipulate ordinary-course brokerage activity and no compensation other than any eventual sale-based commission. No separate analysis fee or other consideration is paid.
- Both the ordinary-course and compensation conditions are supplied.
- Both statutory product definitions contain the exclusion.
Answer: Apply the definitional exclusion instead of automatically treating the discussion as a covered section 10-45 report. Other brokerage, disclosure and truthfulness duties still apply.
The separately paid seller report
A licensed broker is separately engaged for a $300 written probable-selling-price report for a potential seller. Assume the stated purpose is permitted. The report identifies its purpose, real estate interest, method, limitations, preparer interest, actual developer’s name and license number, signature and the substantially prescribed statement.
- This is a separately commissioned product, not the stipulated ordinary-course commission-only example.
- A potential seller is an expressly listed user.
Answer: It fits the stated broker-product route if the analysis and all applicable requirements are satisfied. The supplied contents do not independently prove the underlying evidence is accurate.
A portfolio title hiding origination use
A financial institution calls its request a portfolio review, but instructs that the BPO will be the primary market-value basis for originating a new mortgage secured by the subject real estate. It offers to accept a bold disclaimer.
- The supplied actual use is primary secured mortgage origination.
- The title and willingness to accept a disclaimer do not change the use.
Answer: Do not accept that use as a permitted section 10-45 BPO or CMA. Identify the lawful valuation route actually required; do not assume every alternative label is sufficient.
A lienholder request with a different purpose
A lienholder requests a BPO for an existing-loan workout decision. It will not be the primary market-value basis for any mortgage origination. Assume the broker is authorized, all report requirements can be met, and no other law, program or assignment restriction bars this use.
- The stated facts remove the particular prohibited primary origination use.
- The statute includes the qualified lienholder or third-party category.
Answer: The request is not prohibited merely because a lienholder made it. These assumptions do not establish permission for every workout assignment or every lender purpose.
A planned entity purchase
The developing broker plans to acquire the subject property through an entity in which the broker will have an ownership interest. The report says there is no preparer interest because no offer has been submitted.
- The statute reaches contemplated as well as existing interests.
- The example supplies an actual acquisition plan and ownership stake, not a speculative unrelated possibility.
Answer: Disclose the contemplated interest. The report’s contrary statement cannot be justified by the absence of a submitted offer.
An appraiser number on a broker product
A person licensed both as managing broker and certified appraiser delivers a permitted BPO. The initial page lists only the appraiser license number, and the actual developer’s brokerage identity is omitted.
- This is a broker product, not the person’s separate appraisal assignment.
- Rule 790(a) expressly addresses dual-license initial-page identity; the statute separately requires report identity and signature.
Answer: Use the managing-broker identity and license number as required and complete the developer authentication. The appraiser credential does not repair the omitted brokerage identity.
An exterior observation described honestly
A covered CMA is developed without interior access. The broker uses otherwise supportable information, accurately describes the exterior-only observation and relevant interior-data assumptions, and makes no claim that the interior was inspected.
- The statute requires relevant assumptions or limits and a brief method description.
- This particular checklist does not prescribe an interior visit for every report.
Answer: Describe the actual scope and limits honestly. That does not establish that the scope is adequate for every assignment or that unknown conditions are verified.
A disclaimer above invented evidence
A report includes the required not-an-appraisal statement, but the preparer invents two closed sales and claims an inspection that never happened.
- The alleged facts concern false evidence, not merely different professional judgment.
- Rule 790(b) addresses false, untruthful or misleading statements and inadequate or improper preparation.
Answer: The statement does not prevent discipline for the deficient work. It also cannot convert fabricated data into an adequate method.
“Free” analysis paid with a gift certificate
A broker separately agrees to develop a standalone probable-selling-price report in return for a valuable gift certificate supplied as payment for that analysis. It is not sale- or rental-based compensation, and no other exclusion is supplied. The invoice calls the report free.
- The problem supplies valuable consideration exchanged for the service.
- The exclusion’s compensation condition is not met merely because no cash changes hands.
Answer: Do not use the free heading to claim the commission-only ordinary-course exclusion. Classify and complete the actual assignment under the applicable rules; this is not a finding that any gratuitous gift in any context is compensation.
One missing item in an otherwise complete report
A covered report states its purpose, the interest analyzed, methodology, assumptions and limits, preparer interest and the substantially prescribed statement. It identifies the actual developing broker and real estate license number, but has no signature in any form. Assume the other content and permitted use are adequate.
- Subsection (b)(6) groups the developer’s name, license number and signature.
- Supplying two of those three does not supply the omitted signature.
- Optional exhibits cannot substitute for the missing required subject.
Answer: The developer’s signature is missing. An otherwise polished or well-supported report still has this stated content defect.
Mistakes to avoid
- Every free price opinion is unregulated. Apply both conditions of the statutory exclusion and the other laws governing the actual work.
- Sixteen state questions are all about CMA/BPO. Sixteen of forty belong to the whole Illinois License Act domain.
- A lender’s request is always allowed or always banned. Read the actual purpose and the specific primary-origination limit.
- Any disclaimer wording is sufficient. Use the statutory statement in substantially the prescribed form; it must convey the required distinction.
- The vendor’s logo identifies the developer. Covered reports need the actual developing broker’s name, license number and signature.
- Only an existing ownership interest matters. The report also discloses a contemplated interest.
- No inspection automatically means prohibited preparation. The actual assignment, adequacy and truthfully disclosed scope matter; the checklist does not impose one universal visit.
- A completed checklist proves the number is correct. The analysis must also avoid misleading statements and inadequate or improper preparation.
Check your understanding
These are original teaching questions, not recalled or predicted PSI questions. Answer first, then explain why the other choices fail.
1. Which meaning matches the statutory BPO definition?
- Only a tax assessor’s assessment
- An automatic substitute for every appraisal
- An estimate or analysis of probable selling price of a particular real estate interest
- Any mathematical output with no identified interest
Show answer and explanation
Answer: C. An estimate or analysis of probable selling price of a particular real estate interest
The BPO definition concerns probable selling price, with varying permissible detail. Statutory coverage also depends on the express ordinary-course exclusion.
2. A statutory CMA is defined around which subjects?
- Only replacement cost
- Only the condition of appliances
- Only loan qualification
- Pricing, marketing or financial aspects of a specified real estate interest
Show answer and explanation
Answer: D. Pricing, marketing or financial aspects of a specified real estate interest
A CMA can use comparative market data, the broker’s expertise and other appropriate factors. It is not limited to one computational method.
3. Which conditions describe the express ordinary-course exclusion in both definitions?
- Ordinary-course brokerage activity with no compensation other than sale- or rental-based compensation
- Only a report shorter than two pages
- Any work supplied free by anyone
- Every report related to a listing, even with a separate analysis fee
Show answer and explanation
Answer: A. Ordinary-course brokerage activity with no compensation other than sale- or rental-based compensation
The work and compensation qualifications operate together. Neither a free label nor the existence of a possible future listing alone answers coverage.
4. Who receives section 10-45 authority to prepare or provide the covered product?
- Only a residential leasing agent
- Any owner’s bookkeeper
- A real estate broker or managing broker
- Any assistant using a supervisor’s number
Show answer and explanation
Answer: C. A real estate broker or managing broker
The statute names brokers and managing brokers. Other credentials, sponsorship and actual practice requirements still need attention.
5. A residential leasing agent independently offers a covered paid CMA of a leasehold. Does the presence of a lease itself grant section 10-45 authority?
- Yes, if the agent does not sign
- Yes, because every lessee request qualifies
- No
- Yes, if the report is brief
Show answer and explanation
Answer: C. No
The permitted recipient list does not expand the authorized preparer category. Section 10-45 names brokers and managing brokers.
6. Which request falls within the stated prohibited use?
- A qualifying third-party acquisition-price due-diligence request
- A permitted potential-lessee pricing decision
- A permitted listing-price decision
- Primary market-value basis for a financial institution’s mortgage origination secured by the subject real estate
Show answer and explanation
Answer: D. Primary market-value basis for a financial institution’s mortgage origination secured by the subject real estate
The actual primary secured-origination use is the statutory boundary. A disclaimer or a different report title cannot change it.
7. A lienholder requests a permitted existing-loan workout BPO, not primary origination valuation. All other requirements and restrictions are assumed satisfied. Best answer?
- No written report is needed because a lender asked
- The request is not prohibited merely because the recipient is a lienholder
- Every lienholder use is prohibited
- The report must be called an appraisal
Show answer and explanation
Answer: B. The request is not prohibited merely because the recipient is a lienholder
Section 10-45 includes the qualified lienholder category. The assumed permitted purpose does not dispense with report requirements or other applicable law.
8. What writing format does section 10-45(b) allow for a covered report?
- Paper or electronic writing
- Only the lender’s proprietary paper form
- Only a notarized paper original
- Only a verbal presentation followed by an invoice
Show answer and explanation
Answer: A. Paper or electronic writing
The statute permits either paper or electronic writing, with its required contents. Oral delivery alone does not satisfy this covered-report requirement.
9. Which is a required covered-report subject?
- The buyer’s mortgage approval
- A guarantee of a sale at the stated price
- A universal three-sale minimum
- A brief description of the methodology
Show answer and explanation
Answer: D. A brief description of the methodology
Section 10-45(b)(3) requires a brief description of the method. It does not prescribe the other choices as universal checklist items.
10. The assignment is to analyze a particular leasehold interest. Why can a street address alone be insufficient?
- The report must briefly describe the real estate interest actually analyzed
- The statute bans street addresses
- Only a title insurer can identify any interest
- A leasehold cannot be analyzed
Show answer and explanation
Answer: A. The report must briefly describe the real estate interest actually analyzed
A subject address does not necessarily distinguish the fee interest from the specified leasehold or partial interest. Identify the actual subject of the analysis.
11. The preparer plans a purchase through an entity in which the preparer will own an interest, but no offer exists. What does the covered report need?
- Only a later disclosure after closing
- No interest information until a deed is recorded
- Disclosure of the contemplated interest
- Only a statement of the analysis fee
Show answer and explanation
Answer: C. Disclosure of the contemplated interest
The statutory disclosure reaches an existing or contemplated interest. The supplied actual plan is not erased by the absence of an offer.
12. Whose name, license number and signature does section 10-45(b)(6) require?
- Only the client’s
- The broker or managing broker who developed the report
- Only the software vendor’s
- Any available licensed colleague’s
Show answer and explanation
Answer: B. The broker or managing broker who developed the report
Identify and authenticate the actual developer. A vendor logo or unrelated credential is not a substitute.
13. A dual broker/appraiser licensee prepares a BPO. Which identity must be on its initial page under rule 790(a)?
- Only the client’s name
- Only the appraiser number
- Neither license identity
- Broker or managing-broker name and license number, not the appraiser number
Show answer and explanation
Answer: D. Broker or managing-broker name and license number, not the appraiser number
The rule expressly addresses dual licensees delivering a broker product. The statute separately requires the actual developer’s report identity and signature.
14. Does rule 790(a)’s particular initial-page instruction expressly address every broker regardless of dual licensure?
- No; it specifically addresses a broker or managing broker who is also a licensed appraiser
- It only addresses unlicensed assistants
- Yes, its words omit any dual-license condition
- No covered report ever needs developer identity
Show answer and explanation
Answer: A. No; it specifically addresses a broker or managing broker who is also a licensed appraiser
Keep the rule’s stated dual-license scope separate from section 10-45(b)(6), which requires developer identity and authentication for covered reports generally.
15. A covered report contains the required statement but invents closed-sale evidence. Which conclusion fits rule 790(b)?
- False or misleading and deficient preparation can support discipline
- A later signature always cures the falsehood
- The statement makes the evidence immaterial
- Discipline depends only on the report’s page count
Show answer and explanation
Answer: A. False or misleading and deficient preparation can support discipline
A disclaimer is one content requirement, not permission for false, untruthful or misleading statements or inadequate or improper preparation.
16. What does subsection (b)(8), other appropriate items, do?
- Allows appropriate additional items without replacing the required subjects
- Prohibits supporting exhibits
- Requires exactly eight pages
- Makes subjects (1)-(7) optional
Show answer and explanation
Answer: A. Allows appropriate additional items without replacing the required subjects
The final category permits additional material. It is not an alternative to the preceding required report subjects.
17. A covered report truthfully states that no interior visit occurred. Does the section 10-45 checklist itself require an interior visit for every report?
- No, so every exterior-only report is automatically adequate
- Yes, unless a vendor signs
- No; scope and adequacy still must fit the actual assignment
- Yes, regardless of assignment
Show answer and explanation
Answer: C. No; scope and adequacy still must fit the actual assignment
The checklist requires relevant method and limitations but does not specify one universal interior-inspection rule. Honest disclosure alone does not prove adequacy for every use.
18. For current sponsored BPO work with no applicable compensation exception, which payment channel fits the ordinary rule?
- Direct client payment to any unlicensed assistant
- Through the sponsoring broker
- Any channel if the fee is under $500
- Only through an appraiser’s personal account
Show answer and explanation
Answer: B. Through the sponsoring broker
The ordinary current-work rule uses the sponsoring broker. Statutory exceptions require their own facts; a fee threshold or product label is not such an exception.
19. A valuable gift certificate is expressly exchanged for a standalone BPO, not paid based on a sale or rental. The invoice says free. Does the absence of cash establish the compensation condition of the ordinary-course exclusion?
- Only when the certificate exceeds $1,000
- Yes, only currency is compensation
- No, the stated valuable consideration is payment for the analysis
- Yes, every gift-certificate payment is a gratuity
Show answer and explanation
Answer: C. No, the stated valuable consideration is payment for the analysis
Compensation includes valuable consideration, including coupons or gift certificates. The facts stipulate exchange for the analysis, not a gratuitous gift or sale/rental-based payment; no cash or amount shortcut establishes the exclusion.
20. A covered report has every other required subject, identifies the actual developing broker and license number, and contains no signature in any form. What is the stated missing requirement?
- The client’s notarized authorization on every page
- A universal interior-inspection photograph
- The developer’s signature
- Exactly three closed comparables
Show answer and explanation
Answer: C. The developer’s signature
Section 10-45(b)(6) requires the developing broker’s or managing broker’s name, license number and signature. The hypothetical expressly supplies no signature of any kind; it does not classify an actual electronic signing act.
Common questions
How many Illinois exam questions cover CMA and BPO requirements?
PSI lists this topic in Illinois II.L. The whole Illinois Real Estate License Act domain has 16 of the 40 scored state broker questions. That allocation covers the domain’s other subjects too; PSI does not publish a separate sixteen-question CMA/BPO quota. These practice questions are original teaching items.
What is the difference between a CMA and a BPO?
A statutory BPO estimates or analyzes probable selling price of a particular real estate interest. A statutory CMA addresses pricing, marketing or financial aspects and can draw on comparative data, expertise and other appropriate factors. The definitions differ, but covered products share section 10-45’s use and written-report requirements.
Does every listing-price CMA need the formal section 10-45 report?
First apply the definitions. Both exclude ordinary-course brokerage activity if no compensation is paid other than compensation based on the sale or rental of real estate. A commission-only ordinary listing discussion and a separately paid standalone opinion are not automatically identical statutory products. The exclusion does not make false statements, misuse of confidential information or unauthorized appraisal practice permissible.
Who may prepare the covered product?
Section 10-45 authorizes a broker or managing broker for its identified users and purposes. A residential leasing agent does not gain that authority simply because a lessor or lessee can be a recipient. Sponsorship and supervision requirements still apply, and an unlicensed assistant cannot independently develop and deliver the opinion by borrowing a license number.
Are third-party or lender requests always prohibited?
No. The statute expressly includes specified third-party decisions and due diligence, along with its qualified lienholder or other-third-party category. The exact use matters. A permitted non-origination request does not automatically meet every other law or program requirement, and calling an origination assignment portfolio work does not change the actual use.
What mortgage use is prohibited?
A BPO or CMA cannot be the primary basis for determining the subject real estate’s market value for a financial institution’s mortgage-loan origination secured by that real estate. The rule is more precise than a ban on every bank use, and it is not limited here to a consumer’s newly purchased principal home. A bold disclaimer cannot override the stated use limit.
What must the written report contain?
For a covered product, section 10-45(b)(1)-(7) requires intended purpose; a brief description of the real estate interest; a brief description of the methodology; assumptions or limiting conditions; existing or contemplated preparer interest; the developer’s name, license number and signature; and the substantially prescribed not-an-appraisal statement. Subsection (8) allows other appropriate items. Paper and electronic writing are both permitted.
What is the Illinois not-an-appraisal statement?
Section 10-45(b)(7) requires a statement in substantially this form: “This is a broker price opinion/comparative market analysis, not an appraisal of the market value of the real estate, and was prepared by a licensed real estate broker or managing broker who was not acting as a State certified real estate appraiser.”
It is one required part of the report. It does not authorize a prohibited use, permit invented evidence or make a brokerage product a certified appraisal.
Which license number belongs in the report?
The covered report includes the name, real estate license number and signature of the developing broker or managing broker. For a person who also holds an appraiser license, rule 1450.790(a) specifically requires brokerage name and number, not the appraiser number, on the initial page. Keep that particular initial-page rule separate from the general report-identity requirement.
What interests must the preparer disclose?
Disclose any existing or contemplated interest of the broker or managing broker in the subject real estate interest. A present plan to acquire it through an entity with a personal ownership stake is not irrelevant merely because no offer has been submitted. Other compensation, agency, licensee-status and conflict rules may also apply; this report disclosure is not a universal waiver.
Must every CMA or BPO use three comparables or an interior inspection?
The section 10-45 checklist does not impose a universal three-comparable or interior-visit requirement. The actual method, available evidence, disclosed scope and intended use still need adequate preparation. A lender or other assignment standard can be more specific. Do not borrow a particular appraisal program’s requirements and announce them as the Illinois statute for every broker product.
Can an AVM printout or template complete the report?
It can supply information or a format, but not an automatic compliance conclusion. Identify the actual broker or managing broker who developed the analysis, the required contents and the support for the conclusion. A software logo, unexplained number or another person’s credential does not replace those requirements.
Does being paid separately make the report an appraisal?
Not by itself. Compensation affects the express ordinary-course exclusion, while product classification and authority still depend on the actual assignment and law. Section 10-45 provides a compliant brokerage-product route; it does not give a broker an appraiser credential or make a required appraisal optional.
Can a sponsored broker collect a BPO fee personally?
For ordinary current sponsored work with no applicable statutory exception, compensation is received through the sponsoring broker. Sections 10-5 and 10-20 govern the payment and work relationship. Exceptions such as qualified prior-sponsored work need their own facts; the BPO label or a small fee does not create an exception.
What happens if the report is misleading or inadequately prepared?
Rule 1450.790(b) provides for discipline for false, untruthful or misleading statements, inadequate or improper preparation, or another applicable section 20-20 violation. A disclaimer cannot cure those problems. Whether a specific disciplinary charge or sanction follows requires the actual facts and process; this guide does not impose one.
Can noncash consideration affect the ordinary-course exclusion?
Yes. The Act defines compensation as valuable consideration exchanged for an activity or service, including services, coupons and gift certificates among its examples. A valuable certificate expressly paid in exchange for a standalone analysis is not made irrelevant by calling the report free. A genuinely gratuitous gift presents different facts; do not infer an exchange merely from the word gift.
If the loan is exempt from an appraisal requirement, is the prohibited BPO use automatically allowed?
No. A particular appraisal exemption and section 10-45’s broker-product use limit are separate questions. Appraiser Act section 5-5(g) has a qualified route for an evaluation for a financial institution’s sole use in a transaction not requiring an appraiser under the specified federal rules. That is not blanket permission to relabel a prohibited primary-origination BPO or assume every broker, product or assignment qualifies. Identify the actual lawful authority, institution and program requirements.
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Official sources and scope
Reviewed October 26, 2026. The Illinois statutes and adopted rules below support the report and practice requirements. The checklist applies after statutory coverage is established. The examples make their assumptions explicit and do not approve a particular report, loan product, fee arrangement or professional assignment.
- PSI: Illinois II.L CMA/BPO requirements
- 225 ILCS 454/1-10: definitions, exclusions and compensation
- 225 ILCS 454/10-45: users, uses and report contents
- Rule 1450.790: dual-license identity and deficient reports
- 225 ILCS 458/1-10: appraisal definitions
- 225 ILCS 458/5-5: appraisal authority and qualified exceptions
- 225 ILCS 454/10-5: payment of compensation
- 225 ILCS 454/10-20: sponsored work relationship
- Rule 1450.800: confidential information safeguards
- 225 ILCS 454/15-15: client duties and confidentiality
This is exam preparation, not advice for a specific transaction. State law and the applicable facts control. Our editorial and corrections process explains how to report an issue.