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80 as imposing no timing deadline whatsoever on foreclosure buyers, we find that conclusion to be inconsistent with 1010 Lake Shore." e court further implied that seven months might be too long, absent extenuating circumstances, but remanded to the lower court for a ruling on whether prompt payment had occurred. Seemingly in response, earlier this year the Sixth Division fired back with Quadrangle House Condominium Association v. U.S. Bank, N.A., 2018 IL App (1st) 171713, where payment was made approximately nine months after confirmation. In rejecting the notion that payment must be "prompt," the court stated that 1010 Lake Shore "did not hold that prompt payment is a condition precedent" and that the "payment of post-purchase assessments, when- ever made, is the step necessary" to confirm extinguishment. On the heels of this ruling, this same Sixth Division issued another opinion, V&T Invest- ment Corporation v. West Columbia Place Con- dominium Association, 2018 IL App (1st) 170436, where partial payment was made approximately four months after sale yet less than two months after confirmation. e court first confirmed that assessments were owed as of the first month following the sale, not the first month following confirmation of the sale. However, somewhat confusingly, the court then looked to whether the payment was "prompt," citing to Country Club Estates to determine that payment was indeed prompt, as it was made shortly after the confirmation of the sale. Taking full advantage of the apparent confusion in its neighboring division, the Second Division of Illinois' 1st District Appel- late Court responded in June of 2018 with U.S. Bank, N.A. v. Quadrangle House Condominium Association, 2018 IL App (1st) 171711. To muddy the waters even further, this new case involved virtually the same parties as Quadrangle House Condominium Association v. U.S. Bank, N.A., 2018 IL App (1st) 171713, decided by the Sixth Division earlier in 2018 on a separate unit— thereby creating two "Quadrangle" cases out of the same district, in the same year, with vastly different interpretations. Although the earlier Sixth Division's Quadrangle held that prompt- ness wasn't even a requirement, the new Quadrangle by the Second Division specifi- cally addressed the Sixth Division's apparent change of tune in V&T Investment Corporation v. West Columbia Place Condominium Associa- tion before reasserting its position that prompt- ness is a necessity. In its analysis, the new Quadrangle Court pointed out that sale confirmation occurred in the month following the foreclosure sale, with payments to the association beginning less than two months thereafter, concluding that payment under this factual situation was prompt. e court's focus on the sale confir- mation date, rather than merely the date of the sale itself, implies that it remains an essential factor in determining promptness. However, it seems clear that the only thing truly certain in this evolving area of law is that resolution is far from certain. TransUnion Unveils Solution to Extend Real-Time Credit Offers To meet the evolving needs of consumers, Chicago-based TransUnion announced the launch of Mobile Offers Now. is solution helps financial institutions respond to increas- ing consumer expectations to be served when and where they choose. Mobile Offers Now leverages TransUnion's existing Find My Offer platform to provide consumers with instant access to prequalified credit offers through a simplified, SMS- initiated mobile experience. e technology seamlessly integrates real-time credit decision- ILLINOIS Courts Address Illinois Condo Laws e myriad issues plaguing the Illinois Condominium Law arena have been subject to several recent opinions from two separate divi- sions within the 1st District Appellate Court. Unfortunately, the contrasting court rulings ultimately serve to confuse more than clarify. e string of new cases all focus on a par- ticular section of the Illinois Condominium Property Act, which provides that a foreclo- sure sale purchaser must pay condominium assessments "from and after the first day of the month" following the foreclosure sale to "con- firm the extinguishment" of a condominium association's lien. e Illinois Supreme Court, in 1010 Lake Shore Assoc. v. Deutsche Bank Na- tional Trust Co., 2015 IL 118372, previously ruled that a condominium association's lien for pre- foreclosure sale assessments was owed in full by a foreclosure-sale purchaser who failed to pay any assessments, as the lien's extinguish- ment was never confirmed under the statute. In 2017's 5510 Sheridan Road Condomin- ium Association v. U.S. Bank, 2017 IL App (1st) 160279), where payment was made ap- proximately seven months after confirmation, the Sixth Division 1st District Appellate Court ruled that foreclosur- sale purchasers are not subject to any payment deadline to confirm the extinguishment of a condominium associa- tion's lien, stating that if the General Assembly had wished to include a strict deadline, they would have done so. In contrast, just months later, the Second Division of the same Appellate Court in Country Club Estates Condominium Assoc. v. Bayview Loan Servicing, LLC, 2017 IL App (1st) 162459, instead ruled that "prompt" payment was required. e court stated that to the extent 5510 Sheridan Road "may be read is the difference between annual maintenance costs for the most and least expensive homes in Illinois. Source: Porch.com study entitled "The Cost to Maintain a Home in America," published August 2018 STAT INSIGHT 120%

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