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ARTICLE · 29 JANUARY 2025

Maryland Emergency Regulations

Hogan Lovells Cadwalader
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On January 10, 2025, the Maryland Office of Financial Regulation issued emergency regulations revised to clarify that "passive trusts"...

United StatesFinance and Banking
Mercedes Kelley Tunstall
Mercedes Kelley Tunstall
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On January 10, 2025, the Maryland Office of Financial Regulation issued emergency regulations revised to clarify that "passive trusts" holding residential mortgage loans must obtain a Mortgage Lender License and if the trusts hold installment loans (described below), then they may also need to obtain an Installment Lender License. The emergency regulations were issued on an emergency basis to codify precedent established in case law in Summer 2024.

Please see below for a brief discussion of the loans and trusts that are affected by these regulations.

If the trust (whether it is a new trust or existing trust) holds residential mortgage loans (i.e., loans securing "owner-occupied property having a dwelling on it designated principally as a residence with accommodations for not more than 4 families"), then that trust must obtain a Mortgage Lender license in Maryland.

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