SFA alongside Joint Trades Submit Comment Letter to the Maryland OFR
article by Structured Finance Association
On February 7, 2025, the Structured Finance Association (SFA), alongside other financial trade associations, submitted a letter to the Maryland Office of Financial Regulation (OFR) regarding guidance issued on January 10, 2025. The guidance would require securitization trusts – designated by the Maryland OFR as assignees of mortgage loans in Maryland – to be licensed under Maryland’s Installment Loan Licensing Law and Mortgage Lender Law, as of April 10, 2025. The licensing requirement would apply to open- and closed-end mortgages and is retroactive to existing mortgage-backed securities (MBS) trusts that contain Maryland loans.
SFA and the other trades set forth the legal analysis and policy arguments, and urges the Maryland OFR to withdraw the guidance, or alternatively, delay the implementation by at least one year. The letter notes the expansive nature of OFR’s regulatory interpretation, and states that the regulations would (1) have substantial adverse effects to the non-agency MBS market, (2) reduce the availability of credit in Maryland and (3) increase the cost of credit for Maryland borrowers.
To join SFA’s Maryland State Licensing Task Force, please fill out this join form.