MBA Joint Trade Letter MD OFR on State Licensing
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The Structured Finance Association (SFA), the Maryland Mortgage Bankers and Brokers Association (MMBBA), the Mortgage Bankers Association of Metropolitan Washington, the national Mortgage Bankers Association (MBA), the Housing Policy Council, the American Fintech Council, and SIFMA comment on the emergency amendments to Maryland Regulations .02 and .04 under COMAR 09.03.06 (the “Regulations”). In concert with the Regulations, the Office of Financial Regulation (OFR) issued industry guidance (the “Guidance”) explaining its intent to implement the OFRs understanding of the holding in Estate of Brown v. Ward, 261 Md. App. 385, 396 (2024) decided by the Appellate Court of Maryland.
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