Illinois Reserve Studies Under CICAA and the Condo Property Act

Illinois Reserve Studies Under CICAA and the Condo Property Act

Illinois governs HOAs through the Common Interest Community Association Act, codified at 765 ILCS 160. Condominiums fall under the Condominium Property Act at 765 ILCS 605. The Illinois Department of Financial and Professional Regulation oversees community manager licensing, and the Illinois Attorney General consumer protection division handles HOA complaints.

What 765 ILCS 605 and 160 actually require

765 ILCS 605/9 requires Illinois condo boards to maintain reserves adequate to fund replacement of common elements. The act does not name a specific study cadence, but courts have read the duty broadly. 765 ILCS 160 imposes parallel duties on HOAs that meet the act's threshold.

Both acts require detailed financial disclosure to owners. A board that maintains a current reserve study generally has the cleanest disclosure path.

What good Illinois board practice looks like

Four practices distinguish Illinois boards.

First, commission a reserve study every 3 to 5 years. Cook County weather cycles and the building stock concentrated in older brick construction make 3 year cycles defensible.

Second, document reserve decisions in minutes that survive a records request.

Third, separate operating and replacement reserves at the bank.

Fourth, follow CAI Illinois chapter legislative bulletins. The chapter publishes operational guidance after each session.

Recent Illinois developments

The Illinois General Assembly considered several condo and HOA reform bills in recent sessions. The most consequential proposals tightened transfer fee disclosures and adjusted lien priorities. None impose a state level reserve study mandate yet, but momentum suggests one may follow.

What your board should do this quarter

Take three actions.

1. If your last reserve study is older than 5 years, contract a new one.
2. Confirm operating and reserve accounts are separate.
3. Read the latest CAI Illinois legislative recap.

This is general information for board members, not legal advice. Consult your attorney for your specific situation.

How Manorway helps

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