- Community Associations, Landlord & Tenant Law, Legal Updates
- Illinois
As of October 8, 2025, the 30-day termination notice requirement under the federal CARES Act is no longer being enforced for rental properties with Fannie Mae and Freddie Mac funding. This announcement, in coordination with the Federal Housing Finance Agency (FHFA), marks the end of a pandemic-era rule that impacted landlords and rental property managers across the country.
However, not all CARES requirements have ended. The 30-day termination notice is still mandated for service on all tenants who receive a federal rent subsidy. It is expected that HUD may issue an opinion that all CARES requirements have expired and are no longer enforceable when HUD resumes operations, but for that guidance, we can only wait and hope.
Background: What is the CARES Act 30-Day Notice Rule?
Enacted in March 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act was designed to provide economic relief during the COVID-19 pandemic. Among its many provisions, the Act created temporary protections for tenants living in federally backed or assisted properties, or properties with tenants who receive federal rent subsidy, known as “covered properties.”
These protections included:
- A temporary moratorium on evictions for nonpayment of rent.
- A requirement that landlords at covered properties issue a 30-day notice to vacate before filing an eviction for nonpayment.
Even after the original eviction moratorium expired, this 30-day notice requirement continued to apply to covered properties—those with federally backed mortgages (e.g., Fannie Mae, Freddie Mac, FHA, USDA) or participating in federal housing programs (such as LIHTC or Section 8).
For the past several years, landlords in these categories were required to provide tenants at least 30 days’ written notice before initiating an eviction for nonpayment, even if state law allowed for shorter notice periods.
Recent Change: Fannie Mae and Freddie Mac End Enforcement
In October 2025, both Fannie Mae and Freddie Mac confirmed that they will no longer enforce the CARES Act’s 30-day notice of termination requirement. This change follows guidance from the Federal Housing Finance Agency (FHFA) and years of industry advocacy seeking clarity on when pandemic-era protections would sunset.
With this change, landlords of Fannie or Freddie Mac backed multifamily properties are no longer federally required to provide 30-day notices before initiating eviction proceedings for nonpayment of rent—unless another federal program or state/local law still mandates it.
The full Fannie Mae update can be found here: https://mfguide.fanniemae.com/node/23046?view=recent_guide_communication
What Does This Mean for Illinois Landlords?
For Illinois landlords and rental property managers, this development simplifies the eviction process for properties with Fannie Mae or Freddie Mac funding.
However, it is important to remember:
- CARES requirements for properties with federal rent subsidy programs did not end. While Fannie May and Freddie Mac will no longer be enforcing CARES requirements, there has been no opinion or guidance from HUD regarding notices for tenants who receive federal subsidies. Therefore, the CARES 30 day notice is still required in these cases.
- Illinois notice laws still apply. While the federal 30-day rule may no longer be enforced by Fannie May and Freddie Mac, Illinois state statutes and local ordinances (including the Chicago RLTO and Cook County RTLO) contain their own notice and eviction requirements.
- Confirm your property’s status. If your property is still tied to a federal mortgage program or housing subsidy, confirm whether any program-specific requirements remain in effect.
- Update your internal policies. Property managers and owners in Fannie May or Freddie Mac properties, who incorporated CARES Act notices into their templates or onsite procedures should review and revise those materials or policies to reflect this change.
- Consult legal counsel. Before resuming standard eviction timelines, confirm compliance with Illinois law and any applicable local ordinances.
Legal Resource
The end of the CARES Act 30-day notice requirement represents a return to pre-pandemic norms for many Illinois landlords and property managers. While federal oversight in this area has eased, property owners must continue to comply with Illinois’ landlord-tenant statutes and local housing rules.
Questions about how this change may affect your property, lease compliance, eviction procedures, or other legal concerns? Please call 855-537-0500 or visit www.ksnlaw.com.
Since 1983, KSN has been a legal resource for condominium, homeowner, and townhome associations. Additionally, we represent clients in real estate transactions, collections, landlord/tenant issues, and property tax appeals. We represent thousands of clients and community associations throughout the US with offices in several states including Florida, Illinois, Indiana, and Wisconsin.
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