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Maryland Governor Signs Bill Clarifying and Repealing “All Purchasers” Exemption from Maryland Mortgage Lender Law and Maryland Installment Loan Law

By Francis L. Doorley on April 21, 2026
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In a series of Legal Updates, we previously discussed legislation introduced and passed by the Maryland General Assembly and then signed by Maryland Governor Wes Moore, which provided an exemption for “passive trusts” from the licensing requirements of the Maryland Mortgage Lender Law and Maryland Installment Loan Law.

The version of law that passed the Senate, SB 1026, provided another exemption from the Maryland Mortgage Lender Law and Maryland Installment Loan Law for essentially all purchasers of mortgage loans. However, the House version, HB 1516, did not include this “all purchasers” exemption.  Despite this inconsistency, Governor Moore approved both versions, resulting in a conflict as to the applicability of the Maryland Mortgage Lender Law and Maryland Installment Loan Law to purchasers of mortgage loans.

Almost immediately after Governor Moore signed the conflicting bills, the Maryland Office of Financial Regulation (OFR) issued guidance taking the position that SB 1026 was an inaccurate, earlier version of the proposed law and deemed HB 1516 as the accurate version.

In mid-April 2026, Governor Moore signed SB 784, which will repeal the “all purchasers” exemption and therefore makes the Maryland Code and OFR guidance consistent with each other.  According to the bill, the intent of the bill is to be construed as a “clarifying corrective measure to repeal a provision of law erroneously enacted.”

Notably, SB 784 does not affect the previous legislation that provided an exemption for passive trusts from the licensing requirements of the Maryland Mortgage Lender Law and Maryland Installment Loan Law.  Thus, while SB 784 takes effect on July 1, 2026, the status quo will not change for passive trusts and those relying on the OFR’s earlier guidance.  Those relying on the “all purchasers” exemption, however, will need to reevaluate whether they are required to hold a license in Maryland.

Photo of Francis L. Doorley Francis L. Doorley

Frank Doorley is a partner in Mayer Brown’s Washington DC office and a member of the Financial Services Regulatory & Enforcement group. He handles a broad range of federal and state regulatory compliance matters, primarily for consumer financial product and service providers.  Frank…

Frank Doorley is a partner in Mayer Brown’s Washington DC office and a member of the Financial Services Regulatory & Enforcement group. He handles a broad range of federal and state regulatory compliance matters, primarily for consumer financial product and service providers.  Frank has significant experience advising lenders, consumer finance providers, and investors on compliance obligations under federal and state law. His experience covers a range of products and program structures, including Fintech and marketplace lending programs, retail and home improvement financing, general-purpose unsecured credit, and small business lending and alternative financing. He regularly provides guidance on federal consumer financial laws such as the Truth in Lending Act (TILA), Real Estate Settlement Procedures Act (RESPA) and the CFPB Mortgage Servicing Rules, Equal Credit Opportunity Act (ECOA), Fair Credit Reporting Act (FCRA), Fair Debt Collection Practices Act (FDCPA), Servicemembers Civil Relief Act (SCRA) and prohibitions on unfair, deceptive, and abusive acts and practices (UDAAP).

Read Frank’s full bio.

Read more about Francis L. DoorleyEmail
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  • Posted in:
    Employment & Labor
  • Blog:
    Consumer Financial Services Review
  • Organization:
    Mayer Brown
  • Article: View Original Source

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