ILCS » Chapter 735 · Act 5
Illinois Compiled Statutes

735 ILCS 5/13-115 (2026)

Foreclosure of mortgage

✓ current as of May 2026
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(735 ILCS 5/13-115) (from Ch. 110, par. 13-115)
    Sec. 13-115. Foreclosure of mortgage. No person shall commence an action or make a sale to foreclose any mortgage or deed of trust in the nature of a mortgage, unless within 10 years after the right of action or right to make such sale accrues.
(Source: P.A. 82-280.)

    
Notes of Decisions
Cited in 7 cases (4 in the last 5 years), 2015–2026 · leading case: Schindler v. Watson, 2017 IL App (2d) 160126 (Ill. App. Ct. 2017).
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Schindler v. Watson, 2017 IL App (2d) 160126 (Ill. App. Ct. 2017). “735 ILCS 5/13-115 (West 2004). Thus, plaintiff argues, he should be permitted to treat the sale of the subject property much the same as a default on a mortgage note.”
In re Application of the Cnty. Collector for Judgment & Order of Sale Against Lands & Lots Returned Delinquent for Nonpayment of Gen. Taxes for the Year 2009, 2015 IL App (4th) 140810 (Ill. App. Ct. 2015). “” He cites section 13-115 of the Code of Civil Procedure (735 ILCS 5/13-115 (West 2012)), which provides that “[n]o person shall commence an action or make a sale to foreclose any mortgage or deed of trust in the nature of a mortgage, unless within 10 years after the right of…”
In re Application of the Cnty. Collector v. Eldridge, 2015 IL App (4th) 140810 (Ill. App. Ct. 2015). “" He cites section 13-115 of the Code of Civil Procedure (735 ILCS 5/13-115 (West 2012)), which provides that "[n]o person shall com- mence an action or make a sale to foreclose any mortgage or deed of trust in the nature of a mortgage, unless within 10 years after the right of…”
Chicago Title Land Trust Co. v. Watkin, 2025 IL App (1st) 241354 (Ill. App. Ct. 2025). · cites it 2× “735 ILCS 5/13-115 (West 2022). The mortgage, however, is incident to the underlying debt, as the debt instrument is “the 8 No.”
Nikolaou v. Citizens Bank N.A., 2026 IL App (1st) 250901-U (Ill. App. Ct. 2026). · cites it 3× “” 735 ILCS 5/13-115 (West 2024). Plaintiff alleged that the Bank’s “right to foreclose arose, at the very latest, on June 23, 2009, which was the maturity date of the mortgage.”
JP Morgan Chase Bank N.A. v. Fed. Deposit Ins. Corp., As Receiver for Washington Fed. Bank for Sav. (N.D. Ill. 2022). “§ 1821 (d)(14)(A) (running from the time FDIC was appointed as receiver) and the 10-year limitation period under 735 ILCS 5/13-115 (running from the time a right of action accrued).”
BMO Bank N.A. v. Vaca, 2025 IL App (1st) 241793-U (Ill. App. Ct. 2025). “” 735 ILCS 5/13-115 (West 2022). They disagree, however, on the date BMO’s cause of action accrued.”
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