What does Illinois law say about right of set-off on IRAs?

I can't find it in the regs currently, but our terms & agreements say we cannot offset against:
-an IRA or a tax-deferred Keogh retirement account;
-the debt is created by a consumer credit transaction under a credit card plan;
-the debtor’s right of withdrawal arises only in a representative capacity;
-a payroll account;
-a “special” account (ie. minor, rep payee).

Generally, it's federal law that would govern; i.e. you cannot even take a voluntary security interest in an IRA. Regardless, the right of set off simply is not available because the debt and the deposit are not held by the same person. Technically, the correct name of the customer's IRA is "ABC Bank, Custodian, Past Due Debtor, IRA."

The right of offset simply does not exist unless the debtor and the creditor (deposit account holder) are the same person.