The 1st District Appellate Court of Illinois recently ruled in favor of landlords on an important issue under the Chicago Residential Landlord Tenant Ordinance (RLTO).

Section 5-12-170 of the RLTO requires that a summary of the security deposit interest rates, issued by the Chicago Commissioner of the Department of Planning and Development, be attached to every new lease and renewal, along with the RLTO summary.

For years, landlords who chose not to take a security deposit were still saddled with the burden of obtaining the interest rate summary and adding it as an additional disclosure to each new lease and renewal.

In the new case, Hundley v. WPD Management, LLC, 2023 IL App (1st) 230075, the 1st District Appellate Court held that landlords who do not accept security deposits are not liable under the Chicago RLTO if they fail to attach the security deposit interest rate summary to the Lease.

The Court found that, since the tenants incur no injury or damages by not receiving the security deposit interest rate summary, when no security deposit is paid, such tenants have no standing to bring a claim under the RLTO for failure to attach the summary.

The Appellate Court opinion can be found here.

Legal Resource

Are you considering alternatives to taking a security deposit?  Are you concerned with other security deposit requirements under the Chicago RLTO?

KSN attorneys are familiar with the latest landlord/tenant laws and regulations. We work quickly and efficiently with landlords and rental property managers to discuss evictions, lease reviews, security deposits, and other legal concerns.

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