ILCS » Chapter 815 · Act 160
Illinois Compiled Statutes

815 ILCS 160/2 (2026)

Credit agreements to be in writing

✓ current as of May 2026
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(815 ILCS 160/2) (from Ch. 17, par. 7102)
    Sec. 2. Credit agreements to be in writing. A debtor may not maintain an action on or in any way related to a credit agreement unless the credit agreement is in writing, expresses an agreement or commitment to lend money or extend credit or delay or forbear repayment of money, sets forth the relevant terms and conditions, and is signed by the creditor and the debtor.
(Source: P.A. 86-613.)

    
Notes of Decisions
Cited in 25 cases (2 in the last 5 years), 1994–2022 · leading case: Whirlpool Fin. Corp., a Delaware Corp. v. Jean Sevaux, 96 F.3d 216 (7th Cir. 1996).
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Whirlpool Fin. Corp., a Delaware Corp. v. Jean Sevaux, 96 F.3d 216 (7th Cir. 1996). · cites it 3× “The following actions do not give rise to a claim, counterclaim, or defense by a debtor that a new credit agreement is created, unless the agreement satisfies the [writing] requirements of [815 ILCS 160/2]: * * * H; * * (3) the agreement by a creditor to modify or amend an…”
Klem v. First Nat'l Bank of Chicago, 655 N.E.2d 1211 (Ill. App. Ct. 1995). · cites it 4× “The defendants filed a motion to dismiss the complaint, arguing, inter alla, that section 2 of the Act (815 ILCS 160/2 (West 1994)) barred any action relating to an oral promise to extend credit.”
Help at Home, Inc. v. Med. Capital, L.L.C., D/B/A Medcap, 260 F.3d 748 (7th Cir. 2001). “The ICAA’s Signature Requirement The ICAA provides that [a] debtor may not maintain an action on or in any way related to a credit agreement unless the credit agreement is in writing, expresses an agreement or commitment to lend money or extend credit or delay or forbear…”
K. Miller Const. Co., Inc. v. McGinnis, 913 N.E.2d 1147 (Ill. App. Ct. 2009). · cites it 2× “815 ILCS 160/2 (West 2006). The McAloon court reasoned that because the Agreements Act barred any and all actions at law, traditional equitable remedies, such as equitable estoppel, are also barred.”
Bank One, Springfield v. Roscetti, 723 N.E.2d 755 (Ill. App. Ct. 1999). · cites it 2× “” 815 ILCS 160/2 (West 1998). Section 3 of the Act provides in relevant part: “The following actions do not give rise to a claim, counter [ ] claim, or defense by a debtor that a new credit agreement is created, unless the agreement satisfies the requirements of [s]eetion 2: sji…”
First Nat. Bank in Staunton v. Mcbride Chevrolet, Inc., 642 N.E.2d 138 (Ill. App. Ct. 1994). · cites it 2× “(815 ILCS 160/2 (West 1992).) There is no limitation as to the type of actions by a debtor which are barred by the Act, so long as the action is in any way related to a credit agreement.”
Harris N.A. v. Loren W. Hershey, 711 F.3d 794 (7th Cir. 2013). “See 815 ILCS 160/2; Resolution Trust Corp. v.”
Teachers Ins. & Annuity Ass'n of Am. v. La Salle Nat'l Bank, 691 N.E.2d 881 (Ill. App. Ct. 1998). · cites it 2× “” 815 ILCS 160/2 (West 1996). Section 3 of the Act is captioned “Actions not considered agreements.”
R & B Kapital Dev., LLC v. North Shore Cmty. Bank & Trust Co., 832 N.E.2d 246 (Ill. App. Ct. 2005). “” 815 ILCS 160/2 (West 2004). Under the Act, a credit agreement means “an agreement or commitment by a creditor to lend money or extend credit or delay or forbear repayment of money not primarily for personal, family or household purposes, and not in connection with the issuance…”
LaSalle Bank Nat'l Assoc. v. Paramont Props., 588 F. Supp. 2d 840 (N.D. Ill. 2008). “to Dismiss at 10.) Under the ICAA, “[a] debtor may not maintain an action on or in any way related to a credit agreement unless the credit agreement is in writing .”
McAloon v. Nw. Bancorp, Inc., 654 N.E.2d 1091 (Ill. App. Ct. 1995). · cites it 2× “” (815 ILCS 160/2 (West 1992).) "Credit agreement” is defined, in relevant part, as "an agreement or commitment by a creditor to lend money or extend credit or delay or forbear repayment of money.”
Int'l Supply Co. v. Campbell, 907 N.E.2d 478 (Ill. App. Ct. 2009). “See 815 ILCS 160/2 (West 2006). Second, plaintiffs assert that defendants’ fraud claim is barred by the Frauds Act (also known as the statute of frauds), which precludes a party from enforcing an oral promise (in this case, the promise to allow for a two-year cure period) that…”
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