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Five things the ordinance expects from the second a deposit check clears:
1. Separate account, always. The deposit can’t sit in your operating account — not even “just until things settle.” It has to live in a separate, federally-insured Illinois account, apart from your own money. Commingling is a standalone violation: the tenant doesn’t have to prove they lost a cent. The bank statement tells the story, and “I always meant to move it” isn’t a chapter the judge reads. Where the money has to go →
2. Interest, on the city’s schedule. Hold a deposit past six months and you owe interest — at a rate the City Comptroller resets every single year. Use last year’s rate, skip a year, or “settle up” at move-out instead of paying on schedule, and you’ve created a fresh violation on top of the old one. Late isn’t “even.” Late is its own problem. How the interest works →
3. Receipts and disclosures, on deadlines. You owe the tenant a receipt for the deposit and, within a tight window, the name and address of the bank holding it. Boring, easy to skip — and exactly the technicality that turns a deposit dispute into a deposit lawsuit.
4. The move-out clock is short. Keeping part of it? You get a narrow window to deliver an itemized statement — with the actual receipts or estimates — and a separate deadline to return the rest. Miss it and the right to deduct anything can evaporate, even for damage that was 100% real.
5. Every slip stacks. Here’s the part that stings: these aren’t graded on a curve. Each misstep is its own violation, and the penalty isn’t “give the money back.” It’s return the deposit, plus a penalty of up to twice the deposit, plus the tenant’s attorney’s fees.
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