On April 14, Maryland Governor Wes Moore signed Senate Bill 784, a measure repealing a provision that had exempted certain assignees of mortgages, mortgage loans, and installment loans from licensing requirements under Maryland’s consumer credit licensing laws, including the Maryland Mortgage Lender Law and Maryland Consumer Loan Law.
The bill follows Maryland’s 2025 legislative response to uncertainty over the licensing treatment of loan assignees, secondary-market participants, and passive trust structures. In 2025, Maryland enacted the Maryland Secondary Market Stability Act in response to concerns that certain assignees or trust structures holding Maryland loans could face licensing exposure solely because they acquired or held the loans (previously discussed here). SB 784 states that the repealed provision was “erroneously enacted” in 2025 and removes it in its entirety.
Putting It Into Practice: States continue to focus on licensing as a tool for regulating financial services activity (previously discussed here and here). Maryland’s enactment of SB 784 adds another reminder that licensing exposure often turns on the specific role an entity plays in the credit lifecycle, not simply whether it owns or acquires a loan. Companies acquiring or holding Maryland mortgage or consumer loan assets should review whether their structures qualify for any applicable exemptions and confirm that servicing and borrower-facing activities are conducted through appropriately licensed entities.
