The Maryland Office of Financial Regulation (OFR) has rescinded prior guidance and proposed regulations following the enactment of House Bill 1516, effective April 22, 2025. The new law exempts two types of trusts from Maryland’s mortgage lender and installment loan licensing requirements:

Passive Trusts – Trusts that acquire or are assigned mortgage loans but do not originate, broker, or service them.

Government Trusts – Trusts created by U.S. government entities to acquire mortgage loans.

These changes are effective immediately and apply regardless of the trust’s state of formation. Entities should consult counsel to determine eligibility.

HB1516 also establishes a Licensing Workgroup to review Maryland’s financial licensing framework and recommend improvements by December 31, 2025.

For more information or help evaluating how these changes may affect your licensing requirements, please contact FS Vector.