On May 29, 2025, the Maryland Office of Financial Regulation (OFR) issued final guidance rescinding its prior advisories and proposed regulations concerning the licensing of certain mortgage trusts. This action follows the enactment of HB1516, which took effect on April 22, 2025, and establishes a statutory exemption from Maryland’s mortgage lender and installment loan licensing requirements for two categories of trusts: Passive Trusts, which acquire or are assigned mortgage loans but do not originate or service them, and Government Trusts formed by federal instrumentalities. The statute applies regardless of the jurisdiction under which the trust is formed. OFR also announced the formation of a new Maryland Licensing Workgroup to examine broader licensing structures and recommend changes by year-end. Entities evaluating their licensing obligations should review the new law and consult counsel to determine whether they qualify under the clarified exemptions.