• Changes In Maryland Residential Mortgage Regulations
  • August 24, 2017 | Authors: Marjorie A. Corwin; Robert A. Gaumont; Christopher R. Rahl
  • Law Firm: Gordon Feinblatt LLC - Baltimore Office
  • A number of changes to Maryland regulations governing the mortgage lending industry have become final. Effective July 3, 2017, final regulations governing recordation of security instruments and foreclosure procedures for residential property (see COMAR 09.03.11 and.12 ) allow use of NMLS identification numbers instead of Maryland-issued license numbers in certain disclosures. Effective July 31, 2017, more substantive final changes were made to regulations governing mortgage loan originators (see COMAR 09.03.09 ). These final MLO regulations address a number of topics including: scope of required education courses; format of disclosure for the unique Maryland net tangible benefit form; specific steps the Commissioner must follow when original licenses, renewal licenses, and license amendments are reviewed for approval; when mortgage loan originators may engage in business activities away from a licensed location; limited circumstances when a mortgage loan originator may continue to process mortgage loans after that originator’s license has expired; and requirements for advertising or soliciting mortgage loans. A third set of regulations, which remain in proposed form, would require significant changes to the activities of Maryland-licensed mortgage lenders, brokers, and servicers (see proposed COMAR 09.03.06). There is considerable concern from industry and from some consumer advocates regarding the implications of these proposals, particularly for mortgage loan servicers. We strongly encourage all Maryland Mortgage Lender licensees to study these proposals for the impact they could have on business operations. Please contact Margie Corwin if you would like to ask questions or share thoughts on how these final regulations do, or these proposed regulations could, impact your business activities in Maryland.