Avanti Medical Group, LLC v. BMO Harris Bank, N.A.

Illinois Appellate Court
Civil Court
Banking
Citation
Case Number: 
2014 IL App (2d) 140401
Decision Date: 
Tuesday, December 23, 2014
District: 
2d Dist.
Division/County: 
Du Page Co.
Holding: 
Affirmed.
Justice: 
BIRKETT
Court properly dismissed complaint against bank for breach of credit agreement, as Plaintiffs failed to allege that agreement met signature requirement in section 2 of the Credit Agreements Act. Most obvious noncompliance was lack of mutual signatures on "Amended Terms" document. Section 2 requires that “the relevant terms and conditions” of loan be discernible from documents bearing signatures of both creditor and debtor. (McLAREN and HUDSON, concurring.)