68 Ill. Adm. Code Part 1445 carries the source note: adopted at 35 Ill. Reg. 15585, effective October 1, 2011; amended at 47 Ill. Reg. 8409, effective June 2, 2023. There is no 2024, 2025 or 2026 amendment.

That June 2023 amendment created the firm-licensure architecture at § 1445.35, the fidelity-insurance rules at § 1445.105, and audits at § 1445.125. Sections in force include § 1445.70 (renewal), 1445.100 (fees), 1445.200 (continuing education), 1445.210 (CE curriculum) and 1445.300 (unprofessional conduct).

Why the audit point matters more than it did

Because the statute changed underneath the rules. Public Act 104-0746, effective July 31, 2026, added new Section 55(c-5) to the CAM Act: IDFPR “shall have the authority to audit or inspect any electronic or physical record, account, document, book, form, or file required to be created or maintained by this Act.”

The same Act cut the citation response window from 60 days to 30, and added new lapse and restoration tiers — renewal without examination up to two years past expiration, restoration without examination between two and five years, and the requirements of a new licence beyond five.

So a licensee's recordkeeping obligation is materially more exposed than it was, while the rules implementing it are three years old. That gap is the thing to watch: statutory changes of this kind usually pull rulemaking behind them.

The CE trap that is easy to miss

A separate 2026 bill, HB 4826, would provide that a licensee shall not receive continuing-education credit for any course, seminar or webinar that promotes or instructs on services, treatments, practices or procedures prohibited in Illinois — with the determination made only in the course of a CE or renewal audit, and with IDFPR's prior approval of a provider or course expressly not superseding the restriction.

We could not confirm HB 4826's Public Act number; ILGA's records were unreachable. Treat its enactment as reported rather than verified.

If it is law, the practical consequence for managers is that an approved-provider certificate is no longer a safe harbour. Keep course syllabi, not just certificates, for the 2025–2027 cycle.

Where CAM discipline is actually published

IDFPR publishes a consolidated monthly enforcement report naming each disciplined licensee, city, discipline imposed and reason — revocation, suspension, probation, reprimand, censure, fines. Monthly PDFs exist for all of 2025 and for January through June 2026.

There is no CAM-specific disciplinary digest, so a board checking on a manager has to read the consolidated reports. The CAM Licensing and Disciplinary Board meets the third Tuesday of every other month at 11:00 a.m., alternating Springfield and Chicago; its 2026 meetings ran January 20, March 17, May 19, July 21 and September 15.

What a board can do

Confirm the manager's and the firm's licences are current, and ask what the firm's CE records practice is. A manager whose licence lapses mid-contract is a problem the association discovers at the worst moment.

What to watch next

An IDFPR rulemaking on Part 1445 implementing the new audit and lapse provisions.