The Illinois State Capitol dome in Springfield, where the General Assembly repealed the state’s former public adjuster statute, Article XXXI ¾, in 2021

State legal — Illinois

Illinois Bulletin 2026-01 Omits 1575(f)(4)’s Assignment Exception

The Department’s quotation of 215 ILCS 5/1575(f)(4) stops before the statute’s assignment exception.

By Andy Rouhafzai, Founder2 min read

Photo: Wikimedia Commons / Daniel Schwen

In short

Illinois Company Bulletin 2026-01 asks insurers to name a public adjuster as co-payee, or mail a claim check to one, only when the adjuster's contract contains such a provision. The bulletin's quotation of 215 ILCS 5/1575(f)(4) stops before the statute's closing clause, “except when rights have been assigned to the public adjuster by the insured.” Section 1575(b) makes co-payee status permissive, and under 1575(j) the insurer already holds the executed contract that governs.

Illinois Company Bulletin 2026-01 quotes 215 ILCS 5/1575(f)(4) and closes the sentence a clause before the statute does.

Issued by Director Ann Gillespie and dated January 9, 2026 in its body, though the Department's filename slug reads 01-08-2026, the bulletin renders the fee provision as: the salary, fee, commission, or other consideration "is the obligation of the insured, not the insurer."1 The statute continues past that period: "except when rights have been assigned to the public adjuster by the insured."3 The exception is absent from the bulletin. The bulletin does not flag the omission.

What the Department asks of carriers is narrow: add an Illinois public adjuster as co-payee, or mail a claim check to one, only "when the public adjuster contract the insurance company receives contains such provisions."1 Section 1575(b) says a contract "may specify" co-payee status, and 1575(e)(2) forbids a term requiring the check be issued in the adjuster's name alone.3 Under 1575(j) the carrier already holds an exact copy of your executed contract, so both sides are working from the document that decides whether you stay on the check.3

Read your own form before you forward the bulletin to a desk adjuster who left you off a draft, the way you would audit a Massachusetts policy ahead of its deadline, and check the compensation clause against the cap in each state where you work. The bulletin has been standing guidance since January 9, 2026, alongside a companion bulletin on third-party lead generators issued January 26.4 Neither one changed what 1575(b) permits your contract to say.2

Sources cited

  1. Company Bulletin 2026-01 – Public Adjuster as Co-Payee (Jan. 9, 2026)Illinois Department of Insurance
  2. 215 ILCS 5/ Illinois Insurance Code, Article XLV – Public AdjustersJustia (Illinois Compiled Statutes)
  3. 215 ILCS 5/1575 – Contract between public adjuster and insuredFindLaw
  4. Company Bulletin 2026-02 – Third-Party Public Adjuster Lead Generators (Jan. 26, 2026)Illinois Department of Insurance

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