Illinois · Company Bulletin 2026-02
A Roofer's Lead Voids Your Illinois PA Contract Under 5/1515(e)
Four public adjuster licensing orders on the state's books, and a void-contract clause the NAIC model never had.
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In short
Illinois Company Bulletin 2026-02, signed January 26, 2026, treats a roofer or repair company that hands a public adjuster a homeowner as an unlicensed public adjuster under 215 ILCS 5/1510, which reaches anyone who solicits business for anything of value. The contract that follows is void under 215 ILCS 5/1515(e), a remedy the NAIC model act does not contain. IDOI will now ask in consumer complaints how each contract was solicited.
The IDOI Director's Orders search, filtered to "Public Adjuster Licensing Orders" with the year open to all, returns four documents, the newest dated February 22, 2013.3 Director Ann Gillespie signed Company Bulletin 2026-02 on January 26, 2026, and its operational last paragraph is the part that changes your file.1
The bulletin targets client leads bought or received from an unlicensed third party, usually a roofer who door-knocks a damaged block and hands the homeowner over. 215 ILCS 5/1510 and 5/1515 define "public adjuster" to include anyone who, for compensation or anything of value, directly or indirectly solicits business for another person engaged in the business of adjusting losses.1
Then 5/1515(e): "All contracts entered into that are in violation of this Section are void and invalid."2 Illinois built its Public Adjusters Law on the NAIC Public Adjuster Licensing Model Act, MO-228, adopted in 2005 and amended in the Spring 2025 edition. The model's License Required section contains no void-contract clause. Section 16 answers an unlicensed actor by labeling the conduct a fraudulent insurance act, and leaves the contract alone.4 The model's fee ban at Section 14.A reaches paying an unlicensed person "for investigating or settling claims," and stops short of soliciting.4 5/1510 catches the lead generator standing still, so Illinois never needed the fee ban. 5/1515(e) has been current since P.A. 103-216 took effect on January 1, 2024, and it is an Illinois addition sitting on top of the model.2
The published enforcement record is four documents.
| Order | Date |
|---|---|
| Ivan H. Krpan | April 18, 2011 |
| Frances Lindo / Lightning Construction | October 13, 2011 |
| Marcus Jackson | March 27, 2012 |
| Benjamin Gerdes | February 22, 2013 |
That table is a docket listing, nothing more, and Krpan is a license denial reaffirmed after hearing with costs taxed at $167.20, not misconduct discipline.3 For scale, the same search returns 798 Orders of Suspension and 257 License Revocations across all years.3 All three categories are current, with 85, 88 and 71 suspensions in 2024, 2025 and 2026. Public Adjuster Licensing Orders in those three years: zero. Discipline after 2013 involving a public adjuster would land in the general suspension and revocation categories, which carry no license-type field, so four rows is the limit of what Illinois publishes here, not evidence that none has occurred.
"The roofer is my estimator"
5/1515(d)(3) exempts "a person employed only for the purpose of obtaining facts surrounding a loss or furnishing technical assistance to a licensed public adjuster, including photographers, estimators, private investigators, engineers, and handwriting experts,"2 lifted near-verbatim from Model Section 3.D(3).4
Read the word "only," then read the direction. Every role on that list gets retained after you have a client, to develop a claim you are already on. A lead generator runs the other way and produces the client. A roofer who hands you the homeowner and then bids the repair is not employed only to furnish technical assistance; he has a second job on the loss, and it pays better when your number is bigger. 5/1510 reaches someone who solicits business for the adjuster. (d)(3) exempts someone who assists a claim for an adjuster who already has one.
"I never paid him a dime" does not help, because "anything of value" reaches common ownership, shared expenses, and the prospect of a higher claim payment flowing to the repairing company.1 If the roofer's invoice comes out of a settlement you enlarged, the roofer received value. Retaining proceeds under a void contract can also be misappropriation, a Class 4 felony under 215 ILCS 5/1610, which reaches anyone who misappropriates or converts monies collected as a public adjuster "whether licensed or not."12
What changes on a live file
215 ILCS 5/1585 requires a complete record of each transaction, and the bulletin wants the names and license numbers of any third party that generated the lead inside it.1 License numbers. A blank in that field is itself the record when the lead came from someone unlicensed.
Your contract form has already been read and approved. 215 ILCS 5/1575(j) and 50 Ill. Admin. Code 3118.80(a) bar an Illinois public adjuster from providing services "until their contract form has been filed with and approved by the Director," and every filing is public record under 215 ILCS 5/404.5 What is contested is how the signature on it was obtained, which is what the Department says it "will start asking consumers and the public adjusters" in the complaint process: how the contract was solicited, and whether third parties were involved.1
The bulletin pin-cites 215 ILCS 5/1556(a)(12) for its "knowingly accepting insurance business from ... an individual who is not licensed" ground. Article XLV has no Section 1556; the language is 5/1555(a)(12), which the bulletin's own prose names correctly.2 Kathryn Williams, Assistant General Counsel, takes questions at 312-814-8212.1 The companion bulletin on co-payee checks left 1575(f)(4)'s assignment exception out of its recitation. Massachusetts reaches the same adjuster through the policy form rather than the licensing code, and that audit deadline lands November 5.
Does Bulletin 2026-02 create a new rule for Illinois public adjusters?
No. It states the Department's reading of 215 ILCS 5/1510 and 5/1515, which have carried their current text since P.A. 103-216 took effect January 1, 2024, and announces that consumer complaint intake will now ask how the public adjuster contract was solicited and whether third parties were directly or indirectly involved.
My roofer only writes the estimate. Isn't he exempt under 215 ILCS 5/1515(d)(3)?
It depends on whether he does anything else. The exemption covers a person employed only to obtain facts surrounding a loss or furnish technical assistance to a licensed public adjuster. A roofer who produced the client and then bids the repair is not employed only for that purpose, and 5/1510 separately reaches anyone who solicits business for an adjuster.
I never paid the lead generator anything. Am I clear?
No. Bulletin 2026-02 reads 'anything of value' to reach direct payment, common ownership, shared expenses, and the prospect of a higher claim payment flowing to the repairing company. If the repair invoice is paid out of a settlement you enlarged, value moved.
Has Illinois actually disciplined public adjusters over lead generation?
It depends what the record can show. The IDOI Director's Orders database lists four Public Adjuster Licensing Orders across all years, the newest dated February 22, 2013. Discipline after that date involving a public adjuster would appear in the general suspension and revocation categories, which do not identify license type, so the public record is silent rather than clean.
Sources cited
- IDOI Company Bulletin 2026-02, “Third-Party Public Adjuster Lead Generators” (Jan. 26, 2026)— Illinois Department of Insurance
- 215 ILCS 5, Article XLV — Public Adjusters (incl. 5/1515 and 5/1610; P.A. 103-216, eff. 1-1-24)— Justia US Law
- IDOI Director's Orders search, Public Adjuster Licensing Orders, all years (retrieved Sept. 22, 2026)— Illinois Department of Insurance
- Public Adjuster Licensing Model Act, MO-228 (Spring 2025 edition)— National Association of Insurance Commissioners
- Public Adjuster Contract Review Requirements Checklist, rev. 12/2023, eff. 1/1/2024— Illinois Department of Insurance
Statutory clocks, tracked on every file.
claimOS calendars these deadlines automatically on each claim: acknowledgement, decision, payment, and the suit limitation, each with its code section attached and visible to the whole team.