Industry Advisories - Exemption From Mortgage Lender and Installment Loan Licensure: Correction to Statute - Financial Regulation

June 8, 2026

During its 2026 session, Maryland’s General Assembly passed Senate Bill 784. The bill was signed into law by Governor Wes Moore and takes effect July 1, 2026.

After passage of Maryland’s Secondary Market Stability Act of 2025 (“SMSA”), a certain set of provisions, codified as Md. Code Ann., Financial Institutions Article (“FI”) §11-102, and providing certain exemptions from licensure, were published as law. The General Assembly believed that these provisions had been struck from the final version of the bill as passed. However, because two different versions of the bill—the earlier of which contained FI §11-102—had passed, the provisions were published. Senate Bill 784 eliminates FI §11-102 and ensures that the law as published reflects the actual intent of the General Assembly when the SMSA was passed.

The Office of Financial Regulation wishes to make clear that it will not take enforcement action against persons who, in good faith, had relied upon the provisions of FI §11-102 subsequent to its publication in determining that they were not subject to licensing requirements so long as such persons obtain any required license by July 1, 2026.

Contact

For questions regarding this advisory, please contact Clifford Charland by phone at 410-230-6167 or by email at [email protected].