ANNUAL REPORT

ANNUAL

REPORT

OFFICE OF FINANCIAL REGULATION

Maryland Department of Labor

FOR FISCAL YEAR ENDED JUNE 30, 2023

PRESENTED TO:

Wes Moore, Governor

Aruna Miller, Lt. Governor

Table of ContentsFinancial Regulation Annual Report 2023

TABLE OF

CONTENTS

12 Message from the Commissioner

15 Fiscal Year 2023 Highlights

16 Equity and Access to Financial Services

18 Monetary Recoveries for Consumers and Penalties Assessed

20 Legislative and Regulatory Summary

23 Depository Supervision

24 Bank Supervision

04 List of Abbreviations

06 About the Office

07 Senior Management

08 Management Organizational Chart

09 Accreditation, Innovation and Regulatory Harmonization

SECTION

ACHIEVEMENTS & PRIORITIES

SECTION

INDUSTRY SUPERVISION & CONSUMER PROTECTION

SECTION

OUR OFFICE

Financial Regulation Annual Report 2023 Table of Contents

25 Credit Union Supervision

26 Non-Depository Trust Company Supervision

28 Depository Corporate Activities

30 Licensing

32 Financial Services Supervision

32 Mortgage Supervision

33 Money Services and Consumer Credit Supervision

35 Consumer Services

36 Enforcement

41 Foreclosure Systems Administration

45 State Collection Agency Licensing Board

46 Student Loan Ombudsman

47 Outreach and Education

50 APPENDIX A: State-Chartered and Depository Institutions – Facts & Figures

67 APPENDIX B: Financial Statements – Office Revenues and Expenditures

75 APPENDIX C: Historical Lists of Commissioners and Deputy Commissioners

SECTION

APPENDICES

Page 4 of 84

Financial Regulation Annual Report 2023

LIST OF

ABBREVIATIONS

AARMR American Association of Residential Mortgage Regulators

ASI American Share Insurance

BTFP Bank Term Funding Program

CECL Current expected credit losses

CSBS Conference of State Bank Supervisors

CSU Consumer Services Unit

DHCD Department of Housing and Community Development (Maryland)

FDIC Federal Deposit Insurance Corporation

FFIEC Federal Financial Institutions Examination Council

FOMC Federal Open Market Committee

FPR Foreclosed Property Registration

FY or FYE Fiscal Year or Fiscal Year End

HAF Homeowner Assistance Fund

LID Low-Income Designation

LMI Low-to-moderate income

MMC Multistate Mortgage Committee

MMLA Multistate Money Service Businesses Licensing Agreement

MSCCS Money Services and Consumer Credit Supervision

MTRA Money Transmitter Regulatory Association

NACARA North American Collection Agency Regulatory Association

NCUA National Credit Union Administration

NMLS Nationwide Multistate Licensing System

NOF Notice of Foreclosure

NOI Notice of Intent to Foreclose

OCC Office of the Comptroller of the Currency

OFR Office of Financial Regulation

PPP Payroll Protection Program

ROA Return on assets

SES State Examination System

Financial Regulation Annual Report 2023 Page 5 of 84

We protect Marylanders

through the operation

of a modern financial

regulatory system

that promotes respect

for consumers, safety

and compliance, fair

competition, responsible

business innovation, and

a strong state economy.

OUR OFFICE

Page 6 of 84

Financial Regulation Annual Report 2023

ABOUT THE

• Lenders that issue or service

mortgage loans, personal loans,

vehicle loans, or installment loans.

• Check cashing and money

transmission services.

• Collection agencies and consumer

credit reporting agencies.

• Debt management and credit

repair businesses.

• Sales financing companies and

student loan servicing companies.

• Banks, credit unions, and trust

companies chartered in Maryland.

To fulfill its consumer protection

and regulatory responsibilities, OFR:

• Charters Maryland financial

institutions and licenses or

registers companies or individuals

that provide financial services

to Maryland consumers

(collectively referred to as

“financial service providers”).

• Supervises financial institutions

and financial service providers

by conducting examinations or

investigations to ensure compliance

with state laws and regulations.

• Receives and investigates

complaints from Maryland

consumers and others involving

regulated financial institutions

and financial service providers,

including reports of fraud or

other illegal activity.

Maryland law gives OFR enforcement authority over regulated industries

providing financial services or undertaking consumer collection activities in

the state, specifically including the state-chartered, licensed, and supervised

institutions. The Office possesses its own investigative resources with which to

enforce state law and support the State Collection Agency Licensing Board.

When appropriate, OFR works cooperatively with other state and federal

regulatory organizations and law enforcement agencies to investigate and

prosecute violations of law.

To improve compliance with Maryland law, OFR provides information,

guidance, and assistance to regulated companies and individuals through

advisories, webinars, and other means that emphasize industry’s responsibilities.

Office leadership and staff are in ongoing contact with interested federal,

state and local government and nonprofit agencies to keep them informed of

issues and trends affecting Maryland consumers and financial service businesses.

The Office and the Maryland Student Loan Ombudsman (designated by the

Commissioner of Financial Regulation) conduct outreach on issues under

OFR’s jurisdiction, with a focus on foreclosure and mortgage delinquencies

in the state and student loan issues. Additionally, OFR strives to educate

Maryland consumers about their rights and legal protections.

The Commissioner provides support and information about financial regulatory

matters to the Governor, Secretary of the Maryland Department of Labor,

other state agencies, and the Maryland General Assembly.

The Office of Financial Regulation (OFR or the “Office”) in the Maryland Department of Labor is Maryland’s consumer

financial protection agency and financial services regulator. The Office ensures that the financial services industry treats

Maryland consumers fairly, follows applicable state laws and regulations, and operates in a fiscally sound manner.

The Ofce of Financial

Regulation is Maryland’s

consumer nancial

protection agency and

nancial services regulator.

For a more exhaustive list and exceptions, see the “Regulated Financial Industries and Activities”

page on OFR’s website at labor.maryland.gov/finance/industry/frregulatedind.shtml.

The industries regulated by

OFR include:

OFFICE

Page 7 of 84

Financial Regulation Annual Report 2023

FISCAL YEAR 2023

Assistant Commissioner -

Depository Supervision

Teresa Louro

Assistant Commissioner -

Corporate Activities

Stephen Clampett

Director of

Administration

Michelle Denoncourt

Assistant Commissioner -

Financial Services

Licensing and Supervision

Shereefat Balogun

Commissioner of

Financial Regulation

Antonio “Tony” Salazar

Deputy Commissioner of

Financial Regulation

Vacant

Assistant Commissioner -

Consumer Services,

Outreach and Trend Analysis

Sean McEvoy

Assistant Commissioner -

Policy

Vacant

SENIOR MANAGEMENT

Page 8 of 84

Financial Regulation Annual Report 2023

MANAGEMENT

Director of

Licensing

Arlene Williams

Director of

Money Services &

Consumer Credit

Supervision

Sabrina Brown

Director of

Administration

Michelle Denoncourt

Director of

Mortgage

Supervision

Christine Brooks

Assistant

Commissioner -

Corporate Activities

Stephen Clampett

Assistant

Commissioner -

Financial Services

Licensing &

Supervision

Shereefat Balogun

Assistant

Commissioner -

Depository

Supervision

Teresa Louro

Deputy

Commissioner of

Financial Regulation

Vacant

Director of

Trend Analysis &

Reporting

Brendan Armbruster

Director of

Outreach &

Education

Meredith Merchant

Director of

Consumer Services

Priscilla Wynn

Assistant

Commissioner -

Consumer Services,

Outreach & Trend

Analysis

Sean McEvoy

Director of

Legislative

Response &

Acting Student

Loan Ombudsman

Amy Hennen

Assistant

Commissioner -

Policy

Vacant

Director of

Operations

Cliff Charland

Director of

Enforcement

Dana Allen

Commissioner of

Financial Regulation

Antonio “Tony” Salazar

ORGANIZATIONAL CHART

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Financial Regulation Annual Report 2023

ACCREDITATION, INNOVATION AND REGUL ATORY

Accreditation

The Office has been accredited by the Conference of State Bank

Supervisors (CSBS) for its regulation of state-chartered banks since

July 13, 1992. State bank regulatory agencies must undergo a re-

accreditation examination and audit every five years and submit annual

assessment updates to retain certification. The CSBS Accreditation

Program is designed to encourage the standardization of state-

chartered bank supervision, identify weaknesses, and capitalize on

the strengths of state banking agencies. The process assists OFR in

effectively carrying out its responsibilities in supervising Maryland-

chartered financial institutions, of ensuring that institutions operate

in a safe and sound manner, legal and regulatory compliance, and

providing responsive services.

The Office has been accredited for its mortgage supervision by

CSBS and the American Association of Residential Mortgage

Regulators (AARMR) through their joint accreditation program since

August 31, 2016. Mortgage accreditation serves the same purpose

as banking accreditation but it applies to the supervision of non-

depository mortgage brokers, lenders, and servicers, and it requires,

among other things, that OFR’s policies and procedures in licensing,

examination, enforcement, and consumer complaint response

meet high standards and follow best practices.

The Office received its initial money services businesses accreditation

from CSBS and the Money Transmitter Regulators Association on

June 28, 2022. Maryland is the seventh state financial regulatory

agency (out of all the U.S. states and territories) to apply for money

services businesses accreditation. The money services businesses

program is responsible for supervising the activities of financial service

providers that offer check cashing or money transmission services to

Maryland residents. The Office conducts examinations and investigates

complaints from Maryland consumers about these businesses.

Fintech Innovation Contact

Significant changes continue to occur in the

financial services sector. The Office is committed

to fostering a regulatory environment that supports

a robust, accessible, and equitable financial

system that features responsible innovation and

fair competition. The Office’s designated Innovation

Contact continued to support innovation efforts

in the financial services sector and to facilitate

communication between OFR, entrepreneurs,

and financial technology (“fintech”) companies.

The Innovation Contact is the Office’s point of

contact for entrepreneurs, fintech officials, and

new fintech companies who need assistance in

navigating the licensing process, reviewing

business concepts, evaluating risk management

and compliance management systems,

and providing feedback on business plans.

Additionally, the Innovation Contact is available

to provide information about doing business

in Maryland and to answer questions about

Maryland’s financial laws, rules, and regulations

as they might affect financial products in fields

such as money transmission, virtual currencies,

payments, or lending.

Assistant Commissioner Shereefat Balogun

assumed the role of Innovation Contact in

FY 2023 following the departure of Deputy

Commissioner Greg Thoreson. Throughout FY

2023, the Innovation Contact regularly received

and, with the assistance of the newly formed

High-Quality Standards, Evolving Financial Technologies and Coordinated Supervision

HARMONIZATION

Page 10 of 84

Financial Regulation Annual Report 2023

Innovation and Emerging Issues Committee, responded to inquiries

regarding how Maryland’s financial regulatory system impacted

current and prospective fintech companies operating or seeking to

operate within the State.

Having been informally created in FY 2022 and established under

a formal charter in FY 2023, OFR’s Innovation and Emerging Issues

Committee is an internal cross-functional committee composed of

OFR managers that exists to: (1) support the Innovation Contact as

they seek to foster responsible innovation in the financial services

sector; (2) facilitate communication between OFR staff and entities

offering financial services, (3) ensure the regulatory and supervisory

mandates of OFR are addressed on an intra-agency basis, and (4)

facilitate intra-agency and inter-agency communication regarding

emerging issues.

Networked Supervision

The Office maintains its active participation in multistate

coordination efforts with CSBS and sister state financial regulators

to foster innovation and the achievement of a modern, efficient

regulatory system. These multistate coordination efforts, referred to

as “networked supervision”, provide a more streamlined experience

for industry and regulators through the recognition of standards

and the coordination of activities across state lines.

The Office remains engaged in a multi-year effort to leverage

technology solutions and harmonize laws across states in order to

more effectively supervise financial service providers through a

networked approach with other financial regulators. These efforts

will enable regulated financial service providers to more fully engage

in national-scale activities while protecting consumers and the

financial system in each state. Examples of OFR’s participation

include the following:

• Leading negotiations, along with two other states, as part of a

multistate enforcement action against a payment processing

company for negligent customer data management practices

in processing mortgage payments.

• Continuing participation in the development and deployment of

next-generation technology platforms to streamline licensing,

supervision, and enforcement.

• Participation in the pilot program “One Company One Exam”

for mortgage examinations.

• Continuing participation in multistate mortgage and money

service business examinations.

• Participating as a Phase 1 state under the Multistate Money

Services Businesses Licensing Agreement, responsible for

reviewing elements of money transmitter licensing applications

common to all states.

• Coordinating with other state regulators to harmonize licensing

and supervisory practices.

Office personnel continue to serve in key

roles impacting networked supervision. In

FY 2023, the Director of Operations for the

Financial Services Licensing and Supervision

Unit served as the President and as a member

of the Board of Directors of AARMR and was

recently re-elected to serve another term.

The Office’s Director of Mortgage Supervision

is currently serving on the AARMR/CSBS

Multistate Mortgage Committee which oversees

large multistate mortgage supervision, and the

Office’s Director of Money Service Business

and Consumer Credit Supervision serves on the

Education Steering Committee of the Money

Transmitter Regulatory Association which

establishes national standards for examiner

education. The Office also participates in the

ongoing efforts to modernize the Nationwide

Multistate Licensing System and the State

Examination System.

The Office continues to actively support

multistate efforts to establish new standards

and laws designed to harmonize, where

appropriate, the practices of state financial

regulators. In FY 2023, OFR proposed changes

to Maryland’s Money Transmission regulations.

The proposed changes, which are intended to

implement the Uniform Money Transmission

Modernization Act (“Uniform Act”) model

law, will further harmonize Maryland law with

that of other states and foster uniformity and

coordination in states’ regulation of money

transmitters. The proposed changes received

a number of comments during the notice and

comment period. In response to the comments

received, OFR issued a statement addressing

the significant and relevant issues raised in the

public comments. The Office also modified

the proposed rule to provide greater clarity on

certain issues and address some substantive

concerns. The modified proposal is expected to

be finalized and a final rule issued in FY 2024.

The Office, through Commissioner Salazar,

is taking a lead role in the national efforts to

encourage and assist states in adopting the

Uniform Act.

Financial Regulation Annual Report 2023 Page 11 of 84

Annual message from the

Commissioner, fiscal year

highlights, promoting equity

and access, monetary

recoveries and penalties,

and legislative and

regulatory summaries.

ACHIEVEMENTS &

PRIORITIES

Page 12 of 84

Financial Regulation Annual Report 2023

MESSAGE FROM THE

Antonio P. “Tony” Salazar has been

the Maryland Commissioner of

Financial Regulation since July 5, 2017.

I have the honor of presenting this

Fiscal Year’s (FY) Annual Report to

Governor Moore under the Office’s new

name: “Office of Financial Regulation’’.

After 113 years of being known as

“The Office of the Commissioner of

Financial Regulation’’, the Office’s new

name became effective on July 1, 2023.

Though the Office’s name has changed,

its mission of serving as Maryland’s

consumer financial protection agency

has not.

During FY 2023, OFR continued to

uphold its tradition of strong consumer

protection while also engaging in

effective and impactful regulatory and

supervisory activities, strengthening

its capabilities, and securing significant

legislative results. In that regard, and as

discussed below, the Office broached

the topics of climate change and

equitable access to financial services,

it gave public notice of its enforcement

priorities, and it continued to seek and

implement innovative ways to carry out

its mission. These are topics and trends

that will be continued in FY 2024 and

beyond.

Last year the Office laid out six goals

for FY 2023. The goals revolved around

the following topics and I am happy to

report that the Office made significant

advances in each of these areas:

1. Continuing the Office’s tradition of

strong consumer protection actions.

2. Engaging in effective and impactful

regulatory and supervisory activities.

3. Enhancing community and

industry engagement and

education.

4. Enhancing investment in staff.

5. Understanding data availability,

needs and usage.

6. Collaborating with sister state

regulators.

Many of the Office’s activities

advanced one or more of its goals. For

example, OFR continued pursuit of

several ongoing enforcement actions

and commenced new investigations

and cases. Some of the existing

cases involve complex legal issues

surrounding the rules to be followed

by non-banking companies who

partner with out-of-state banks to lend

in our state at rates that would not

be permitted by Maryland law. The

Office initiated 52 new investigations

involving violations of Maryland

consumer financial laws and issued

an Order to shutter the operations

of an entity operating a non-licensed

financial institution. The Office’s

licensing, supervisory and consumer

service units each identified and took

steps to remedy illegal, unlicensed,

and other harmful activities resulting

in changes in the business practices

and consumer restitution. Of note

was the Office’s leadership role in

concluding a multistate settlement

agreement with ACI Worldwide,

Inc. where OFR and other state and

federal regulators responded to the

company’s transmission of more

than 1.4 million erroneous mortgage

payment debit instructions affecting

over 478,000 consumers nationwide

and approximately 14,000 consumers

in Maryland. These and other actions

detailed below illustrate the Office’s

continued commitment to strong

consumer protection and impactful

regulatory activities.

During FY 2023, the Office issued a

revised set of enforcement priorities

to improve the allocation of its

investigative and legal resources. In

particular, the list of enforcement

priorities is intended to identify the

types of behaviors and practices OFR

determines to be the most abusive

and harmful to Maryland consumers

and the financial services industry.

The priorities are described below

and topically cover: new or innovative

products or services, bank-fintech

partnerships, recidivism, systemic

issues resulting in widespread

consumer harm, and redlining and

discrimination in lending.

Legislation pursued and supported

by OFR during the Maryland

Legislature’s 2023 session was

consequential as it ranged from

bills that changed the Office’s

name and, notably, the manner in

which it collects revenue from non-

depository entities, to important

advances for consumers in the

realms of equity and mortgage

lending.

COMMISSIONER

Page 13 of 84

Financial Regulation Annual Report 2023

Working with the Administration, the Office helped ensure the

passage of Governor Moore’s groundbreaking Access to Banking

Act (House Bill 548). The Act represents an innovative approach to

the objective of ensuring that all Marylanders and their respective

communities have access to financial services. The Act seeks to

improve communities’ access to physical branches of depository

institutions by providing depository institutions with incentives to

open and maintain their branches in low-to-moderate income (LMI)

communities, while also authorizing the Commissioner to utilize funds

from the Depository Special Fund to seed a public/private venture

fund that will have a mission of seeking financial technology products

and companies that can be instrumental in increasing lending to small

businesses in such communities.

The Office obtained passage of a bill that helps it meet its goal of

operating a modern regulatory system. The new law puts Maryland

at the forefront of the movement to improve the licensing of non-

depository entities by eliminating the concept of “branch” licenses,

and the paperwork, costs, and other administrative efforts that are

associated with issuing such licenses. It replaced the current licensing

and fee structure with a modern structure, one that involves the

issuance of one license per entity (instead of licensing each branch

location) and permits OFR to issue annual assessments in order to

fund its operations. The law created a reinstatement process allowing

licensees to renew their expired licenses rather than reapplying, and

it clarified requirements pertaining to the use of trade names. The

changes will guarantee the funding of OFR’s future non-depository

activities and are anticipated to reduce the burdens on regulated

industries while also streamlining the Office’s administrative

workflow.

With the passage of House Bill 1150, which was sought by OFR,

the Legislature modified Maryland’s mortgage lending laws to

clearly provide that shared appreciation arrangements are to be

governed by Maryland’s mortgage laws. While OFR believed that

such products were covered by the State’s mortgage laws, it sought

the clarification to avoid litigation and in response to products that

market participants argued were not covered by such laws. The

new law is intended to protect consumers from the risks inherent in

these complex transactions and OFR anticipates that the new law

will protect and benefit consumers by establishing a clear licensing

and regulatory framework for oversight of transactions that are

sometimes structured to avoid disclosure and other consumer

protection requirements.

The Office was also active on the regulatory front as it publicly

pursued two new regulations and commenced work on two others.

The publicly issued regulations dealt with foreclosure procedures

and, importantly, changes to the money transmitter regulations that

are designed to complete Maryland’s adoption of the Conference

of State Bank Supervisors’ (CSBS) Model Money Transmission

Act. In FY 2024, the Office intends to issue regulations on shared

appreciation mortgages and on the Office’s use and sharing of other

states’ mortgage examinations.

I, and other members of OFR, remained active in leadership

positions in multistate regulatory organizations. These positions

enhance our Office’s capabilities, enable OFR staff participation

in the development of national standards and policy and, overall,

strengthen our Office’s ability to protect consumers and reach our

goals. For example, I have been active in the Conference of State

Bank Supervisors, serving as the Vice Chair of the Non-Depository

Supervisory Committee. At the CSBS 2023 annual meeting, I was

elected to serve as the group’s Vice Chair. As

a member of the Federal Deposit Insurance

Corporation’s (FDIC) Advisory Committee of

State Regulators, I directly provided advice

and information to the Chairman and Board

of the FDIC. I also assumed a post as a

representative of the National Association of

State Credit Union Supervisors (NASCUS) to

the FBIIC (Financial and Banking Infrastructure

Information Committee). It is a post that keeps

me, and through me the Office, connected with

technology and cyber issues at the highest

levels of government. Other OFR staff, including

Directors Charland, Allen, Brooks, and Brown,

regularly participate in interstate discussions

and also serve as officers of multistate

organizations. Student Loan Ombudsman

McEvoy announced his departure from OFR in

FY 2023 and would be replaced by Director

of Legislation Amy Hennen who assumed the

role as acting Student Loan Ombudsman. As

Student Loan Ombudsman she engaged in

significant outreach and discussions with other

state and federal student loan organizations,

agencies and ombuds offices. All in all, OFR

staff increases the Office’s effectiveness when

they participate in and coordinate with other

state and federal agencies and organizations.

The State Collection Agency Licensing Board

again operated with full membership as it

gained two new members in Ms. Traci Rezvani

who joined the Board in the role of a consumer

representative and Mr. Shawn Kennedy who

joined the Board in the role of an industry

representative.

The Office took a number of steps to meet

our engagement goal including, continuing to

meet with consumer advocates in large and

small group settings, holding over 40 outreach

events, issuing 15 advisories on various topics,

and adding the foreclosure information that we

make available on our website to the State’s

Open Data Portal. The Office continued to

be supportive of and worked closely with

the Maryland Department of Housing and

Community Development on its Homeowner

Assistance Fund, and ongoing foreclosure

prevention initiatives. The Office held its third

annual “Regulatory Highlights” webinar, a

live-streamed event for regulated industries

and interested consumer groups, during which

OFR staff and leadership provided legislative,

supervisory, and enforcement updates. As

noted above and in her separate report,

Ombudsman McEvoy and Acting Student

Loan Ombudsman Hennen also undertook

a number of meetings and actions, including

providing consumers with the opportunity

for video meetings and engaging with the

Maryland Center for Collegiate Financial

Page 14 of 84

Financial Regulation Annual Report 2023

Wellness to inform borrowers of changes to federal payment and

waiver programs. In sum, those actions and the others detailed in this

report are all part of OFR’s commitment to stay connected to and

engaged with the public and key constituents. Finally, I continued

to be a member of the Maryland Financial Education and Capability

Commission.

The Office’s Licensing Unit again processed over 20,000 license

applications during the fiscal year. That accomplishment was made

possible by the hard work and dedication of the Licensing Unit staff.

Mortgage lenders/servicers, money service business, and consumer

credit companies that are licensed by the Office are subject to

periodic examinations to ensure that they are sound and operating

according to law. Those examinations are carried out by OFR’s

examiners from the Mortgage Supervision and Money Services

and Consumer Credit Supervision Units. Members of these staffs

distinguished themselves not only by the volume of their work,

having completed over 200 examinations of licensed entities, but

also by the quality of their work as leaders and/or participated in

multiple multi-state examinations, and some examiners lent their

expertise to the state system by providing training and or

IT knowledge.

The Office’s Consumer Services Unit continued to resolve

consumer complaints and finalized the implementation of the new

State Examination System (SES). The SES, which is also used by

the financial services supervisory unit to conduct examinations, is an

integral piece of state financial regulators’ networked supervisory

strategy. While it saw a 19% increase in complaint volume, OFR’s

Consumer Services staff was able to successfully recover $125,425

for Maryland consumers.

The States’ banks and credit unions performed well during the

fiscal year despite the headwinds caused by the continuing

increase in interest rates and the liquidity scare that arose in the

early Spring of 2023. As in recent past years, the vast majority

of Maryland’s state-chartered institutions were controlling risks,

were well managed, capable of withstanding business fluctuations,

and operating in substantial compliance with applicable laws and

regulations. However, as explained in the Depository Supervision

section of this report, that conclusion was not one that would’ve

been anticipated in the Spring of 2023 when the confidence in the

nation’s banking system suffered a serious blow upon the sudden

failure of two large, regional banks from California and New York.

Those failures caused significant distress to the country’s banking

system and OFR and other state and federal regulators worked

diligently during that period to continuously monitor institutions’ and

market conditions, implement new programs to enhance institutions’

liquidity, and review the circumstances that lead to the failures

to guide future policy. Fortunately, Maryland and its consumers,

businesses and financial institutions avoided serious repercussions

from the failures. Maryland’s financial institutions continued providing

uninterrupted financial services to their customers and by and large

they experienced satisfactory financial results, ending the fiscal year

in a fundamentally sound condition. Overall, it was a stressful time.

I would like to commend OFR’s depository staff for their hard work

during long days and thank the Maryland Bankers Association,the

MD|DC Credit Union Association, and their receptive members for

their cooperation and the coordination they provided to OFR and

other regulators.

Internally, OFR worked diligently to fill vacancies and to provide its

staff with the modern technology they need to ensure that the Office

operates efficiently and effectively and remains

a leader among state regulators. The Office

increased the amount of its budget allocated to

employee training and development and saw

employees take advantage of the opportunities

that were offered.

Looking to FY 2024, the Office again undertook

a structured strategic planning process that saw

it following Governor Moore’s directive to be a

State agency that supports the goal of “leaving

no Marylander behind.” To that end, and

working with Labor Secretary Wu, the Office

adopted FY 2024 goals that are as follows:

1. Protect Maryland consumers from financial

harm and educate them to make informed

financial decisions.

2. Modernize Maryland’s financial regulatory

system to adapt to rapid change and to be

efficient and effective for all stakeholders

through the use of technology and data.

3. Promote an equitable and inclusive financial

system that leaves no Marylander behind

and fosters broader participation by low to

moderate income communities and small

businesses in the financial system and state

economy.

4. Enhance employee engagement and

empower employees to execute with

excellence.

5. Strengthen the Office’s collaboration with

sister state regulators and other Maryland

agencies, to create a system that is

networked, transparent, and excellent.

In closing, I am honored to have had the

privilege of serving as Maryland’s Commissioner

of Financial Regulation for the past six years.

I am thankful to Governor Moore and Labor

Secretary Wu for giving me the opportunity

to continue serving in that capacity and look

forward to working with them, Maryland’s

legislators, OFR’s staff, and its stakeholders as

we all strive to protect Maryland’s consumers

and generally improve its consumer financial

services sector.

Antonio P. “Tony” Salazar

Commissioner of Financial Regulation,

State of Maryland

Annual Report

Fiscal Year Ended

June 30, 2023

Page 15 of 84

Financial Regulation Annual Report 2023

FISCAL YEAR 2023

Consumer Recoveries and Penalties Assessed: The Office collected a total of $358,539 in combined monetary

recoveries for Maryland consumers and civil penalties against companies and/or individuals that were identified to have

violated various State laws and/or regulations.

Equity and Access: The Office collaborated with Governor Moore to gain passage of the Access to Banking Act, a

new law that seeks to encourage financial institutions to retain and grow access to banking services in low-to-moderate

income communities.

Legislation: Three bills initiated by the Office in the 2023 General Assembly session became law.

Regulation: The Office finalized changes to the regulations for Foreclosure Procedures for Residential Property. The new

regulations provide clarity regarding the Commissioner’s authority to address violations of law or regulation, the rights of

homeowners, and the responsibilities of mortgage services.

Depository Institutions: Maryland-chartered banks’ total assets increased by 5.38% to $49.7 billion and Maryland-

chartered credit unions’ total assets increased by 2.5% to $8 billion.

Licensing: The Office licensed or registered 20,313 individuals and businesses, and collected $40,300 in penalties due to

prior unlicensed activity.

Financial Services Supervision: The Office completed 184 examinations of mortgage and money transmission business.

Mortgage Supervision assessed $208,375 in monetary recoveries for Maryland consumers from violations identified

during mortgage examinations.

Consumer Services: The Office was successful in recovering restitution payments of $125,425 for Maryland consumers

through the investigation and resolution of consumer complaints.

Enforcement: The Office assessed $27,840 in monetary recoveries for Maryland consumers and collected $40,162 in

penalties from a credit service business for unlawful practices associated with mortgage loan modification consulting

services.

Outreach and Education: The Office’s Outreach Unit organized or participated in 42 events, conferences, and stakeholder

meetings.

Data and Reporting: The Office implemented a process for monthly postings of foreclosure data on the Maryland Open

Data Portal.

Student Loan Ombudsman: The Ombudsman began offering video chat appointments for student loan borrowers and

presented to four different stakeholder groups.

HIGHLIGHTS

Page 16 of 84

Financial Regulation Annual Report 2023

EQUITY AND ACCESS TO

As part of the Office’s consumer protection and regulatory

mandate, OFR seeks to promote principles and practices that

are designed to ensure that Maryland’s financial services sector

operates equitably and that all Marylanders have access to safe

and well-regulated financial services.

Use of Data

In FY 2023, the Office started to utilize data and statistics in new

ways to better understand the demographics of banking, lending

and foreclosure in Maryland and to identify patterns indicating

potential disparities or inequities. For example, mortgage and

foreclosure data may reveal redlining, reverse redlining, or other

discriminatory or disparate lending practices.

Sources of data include the FDIC’s Unbanked and Underbanked

Survey, Federal Financial Institutions Examination Council (FFIEC)

branch location data, Home Mortgage Disclosure Act lending

data, Mortgage Bankers Association mortgage lending and

default data (obtained through the Conference of State Bank

Supervisors), and call reports from supervised

companies. The Office also analyzes consumer

complaint data from its own Consumer Services

Unit, as well as from federal agencies, including

the Consumer Financial Protection Bureau,

Federal Trade Commission, and Office of Federal

Student Aid in the U.S. Department of Education.

Additionally, OFR conducts routine analyses of

address-level data from the Maryland Foreclosure

Registration System, with a focus on geographic

and demographic data obtained from the U.S.

Census Bureau and the Maryland Department of

Information Technology.

The Office’s analyses are primarily used for

decision-making, strategic planning, policy

development, and for various supervisory

activities, such as examinations and investigations.

The Office shares statewide foreclosure data

FINANCIAL SERVICES

Page 17 of 84

Financial Regulation Annual Report 2023

publicly on the Foreclosure Data Tracker page of OFR’s

website and data aggregated by county and zip code is

shared on the Maryland Open Data Portal. In FY 2024,

OFR will explore if additional aggregated data or reports

can be made available to a wider audience in an effort

to improve transparency and better inform the public

and interested stakeholders, including policymakers and

researchers.

Planning and Policy

The Office’s FY 2024 strategic plan, developed in the

last quarter of FY 2023, included several objectives

and tactics focused around issues of equity and access.

As an example, one of OFR’s goals in the next fiscal

year is to “promote an equitable and inclusive financial

system that leaves no Marylander behind and fosters

broader participation by low-to-moderate income (LMI)

communities and small businesses in the financial

system and state economy.”

The 2021 FDIC National Survey of Unbanked and

Underbanked Households shows the importance of

policies that promote equitable access to safe and

affordable deposit accounts at insured institutions.

• Approximately 5.9 million or 4.5% of U.S. households

identified as “unbanked”, meaning that no one in the

household had a checking or savings account at a

bank or credit union. In Maryland, 5% of households

were unbanked.

• Differences in unbanked rates between Black and

White households and between Hispanic and White

households were present at every income level. In

Maryland, 10.6% of Black households were unbanked

as opposed to 1.8% of White households.

• The most cited reason from survey respondents for

why they do not have a bank account was “Don’t

have enough money to meet minimum balance

requirements”.

The Office is exploring strategies to improve accessibility

of banking services in Maryland’s LMI communities and

expanding outreach efforts, particularly to vulnerable

populations who often face systemic discrimination

or may not have the opportunity to access financial

education resources.

Additionally, enforcement priorities were revised in FY

2023 to explicitly state that ensuring equal access to

lending opportunities, particularly mortgage lending, for

everyone regardless of race or national origin is a focus

for the Office. This includes investigations of complaints

alleging violations of the Equal Credit Opportunity Act,

Fair Housing Act, and other anti-discrimination laws.

Enforcement priorities are described in greater detail in

the Enforcement section of this report.

In the FY 2023 General Assembly Session, OFR assisted

with passage of Governor Moore’s Access to Banking

Act. The Act promotes the growth of financial services in

LMI communities through the use of assessment credits

to Maryland state-chartered banks and credit unions

that operate branches in LMI communities; and through

the establishment of a venture fund to invest in financial

innovations that develop opportunities for banking

institutions and credit unions to better serve the needs of

LMI communities. More information about this Act is in the

Message from the Commissioner, Legislative Summary,

and Depository Supervision sections of this report.

Page 18 of 84

Financial Regulation Annual Report 2023

MONETARY RECOVERIES FOR CONSUMERS AND

Consumer Recoveries

Total Consumer Recoveries FY 2023

$174,663

Monetary recoveries for consumers result from

OFR’s commitment to protect the public from

economic harm caused by companies or individuals

providing financial services in Maryland. During FY

2023, the Office recovered and provided $174,663 in

restitution to consumers across all Units.

Total Consumer Recoveries Fiscal Year 2023

$174,663

Penalties Assessed

Total Penalties Assessed FY 2023

$183,876

During FY 2023, OFR investigated or examined

companies and/or individuals that were identified

to have violated various State laws and/or

regulations, and as a result of those investigations

and examinations, collected assessed penalties of

$183,876.

Total Penalties Assessed Fiscal Year 2023

$183,876

TOTAL

$358,539

PENALTIES ASSESSED

Financial Regulation Annual Report 2023 Page 19 of 84

License No. License Type No. of Penalties Instances of Restitution

1 Sales Finance 3

2 Consumer Loan 1 2

3 Installment Loan

4 Collection Agency 11 4

6 Mortgage Lender 74 23

8 Credit Reporting Agency 1

9 Check Casher

10 Bank 3

11 Credit Union 16

12 Money Transmitter 12

14 Debt Management Service Provider

15 Debt Settlement Service Provider

19 Licensed Check Casher

26 Mortgage Originators

28 Credit Services Business 1 1

29 Check Casher Registration

34 Registered Exempt Collection Agency

36 Exempt Mortgage Lender - Registered

N/A Other 2 28

TOTAL 89 93

MONETARY RECOVERIES

Below is a breakout of the number of penalties assessed and instances of restitution by type of license during FY 2023.

Page 20 of 84

Financial Regulation Annual Report 2023

LEGISLATIVE AND REGULATORY

Legislative Summary

The Maryland 2023 General Assembly

adjourned on April 10th, concluding a

successful legislative session. The Office

proposed three bills, worked closely

with the Governor’s Office on another

bill, and provided technical support on

other legislation focused on improving

the Office’s efficiency, clarifying

Maryland laws under its jurisdiction,

enhancing consumer protections, and

promoting a safe and healthy financial

services industry. Those bills and other

notable legislation that passed during

the 2023 session of the Maryland

legislature are described below.

HB 379/SB 929: Commissioner of

Financial Regulation - Name and

Organization of Office

Effective date: July 1, 2023

This law, initiated by the Commissioner,

changes the name of the Office under

the Commissioner of Financial Regulation

in the Maryland Department of Labor

to the “Office of Financial Regulation’’.

The law also establishes a new Deputy

Commissioner position that is for financial

services licensing and supervision (aka,

non-depository activities).

HB 686: Financial Regulation -

Modernizing Licensing of Non-

Depository Institutions and Elimination

of Branch License Requirements

Effective date: July 1, 2023

This law, initiated by the Commissioner,

eliminates the requirements for collection

agencies and certain non-depository

financial institutions to maintain separate

licenses for their branch locations. It

authorizes them to conduct business at

multiple licensed locations under a single

license. Financial service businesses will

pay one licensing fee that will include

all branches plus an assessment the

amount of which is determined by the

Commissioner each year. The assessment

will be based on actual costs to regulate

the business, including risk and size. All

licensed locations will be covered under

a business’s bonding requirements to

ensure consumer protection. The Office

intends to draft and issue appropriate

implementing regulations.

HB 1150: Commercial Law and

Financial Institutions - Credit Regulation

- Shared Appreciation Agreements

Effective date: July 1, 2023

This law, initiated by the Commissioner,

makes certain that shared appreciation

agreements are subject to the Maryland

Mortgage Lender Law and other

provisions of law that regulate certain

loans of single extensions of closed end

credit and revolving credit plans. The

Office will adopt regulations regarding

the enforcement of and compliance with

provisions of law that regulate shared

appreciation agreements.

HB 548/SB 550: Financial Regulation -

Maryland Community Investment

Venture Fund - Establishment

(Access to Banking Act)

Effective date: July 1, 2023

This law, initiated by the Governor,

establishes the Maryland Community

Investment Venture Fund. The Fund is

to be established by the Commissioner

with seed money from the Depository

Special Fund. Under the new law,

Maryland-chartered banks and credit

unions with branches in LMI census

tracts will be able to apply for credits

toward the annual assessment amount.

The law encourages banks and credit

unions to deposit the value of the credit

into the venture fund and permits the

Commissioner to match some or all

these funds. The Venture Fund will

be used to provide seed funding to

small businesses developing new

access to capital for under-resourced

small businesses located in LMI

communities.

SB 516: Cannabis Reform

Effective date: upon enactment

This law establishes a regulatory and

licensing system for adult-use cannabis

and requires the Administration,

by July 1 2023, to convert medical

cannabis licenses to licenses to

operate a medical and adult-use

cannabis business. The Office will

monitor the banking sector for any

issues with banks and credit unions

that chose to provide banking services

to licensed cannabis businesses.

HB 384: Income Tax - Student Loan

Debt Relief Tax Credit - Alterations

Effective date: July 1, 2023

This law increases the total amount of

credits against the State income tax

that the Maryland Higher Education

Commission may approve in a

taxable year for student loan debts.

Additionally, it extends from two years

to three years, the period of time that

an individual who claims the credit

has to prove that they used the credit

to repay the individual’s student loan

debt. The Student Loan Ombudsman

within OFR will monitor and advise

Marylanders on this issue.

HB 680: Institutions of Higher

Education - Transcripts - Prohibition

on Punitive Measures Related to

Student Debt

Effective date: July 1, 2023

This law prohibits an institution of

higher education from refusing to

provide a current or former student

with a transcript or taking other

punitive measures regarding a

student’s transcript request because

the student owes a debt to the

institution of higher education. The

Student Loan Ombudsman within

OFR will monitor this issue.

Changing Legal Environment and Innovative Regulatory Advancements

SUMMARY

Financial Regulation Annual Report 2023 Page 21 of 84

LEGISLATIVE & REGULATORY

ADVANCEMENTS

HB 913: Financial Institutions - Student Financing

Companies - Required Registration and Reporting

Effective date: October 1, 2023

This law requires student financing companies to register

with the Commissioner of Financial Regulation before

providing services in the State; requires a student

financing company to renew its registration on an annual

basis; authorizes the Commissioner to adopt registration

procedures for student financing companies, which

may include certain fees; and requires student financing

companies to annually report certain information, to be

made publicly accessible on a certain website, to the

Commissioner beginning March 15, 2024. The Office

will create a registry with NMLS for student financing

companies to register and a portal for these companies to

provide the required information. The Office will post this

information on its website and report it in the Student Loan

Ombudsman Annual Report.

SB 106: Courts - Judgments - Exemptions

From Execution

Effective date: October 1, 2023

This law exempts up to $500 in a deposit account or

other account of a judgment debtor held by a depository

institution from execution on the judgment without an

election by the debtor to exempt the money. Further, it

establishes procedures a depository institution is required

to follow on receipt of a writ of garnishment or other levy

or attachment under certain circumstances. The Office will

monitor licensees who may be impacted by this legislation.

HB 127: District Court - Small Claims - Enforcement

of Money Judgments

Effective date: October 1, 2023

This law prohibits the District Court, in aid of enforcement

or execution of a money judgment resulting from a certain

small claim action, from ordering the appearance of an

individual for an examination or ordering an individual to

answer interrogatories. The Office will monitor licensees

who may be impacted by this legislation.

Regulatory Summary

The Office successfully pursued two noteworthy regulatory

initiatives during the fiscal year:

Foreclosure Procedures for Residential Property

Effective date: March 1, 2023

On December 16, 2022, the Commissioner adopted

amendments to Regulations in COMAR 09.03.12

Foreclosure Procedures for Residential Property. The

changes to the regulation were made final in 49:26 Md.

R. 1078-1079 (December 16, 2023). The amendments

were issued in order to harmonize certain regulations

that are inconsistent or contradictory as a result of recent

changes within the Maryland Annotated Code, update and

generally improve existing requirements and forms within

the mediation process, and update provisions regarding

the Commissioner’s authority to address violations of

law or regulation. The changes are intended to reduce

procedural gaps within the foreclosure mediation process

and to provide greater clarity regarding the rights and

responsibilities of mortgage servicers and consumers.

Money Transmission

Effective date: FY 2024

On February 24, 2023, the Commissioner proposed

amendments to Regulations in COMAR 09.03.14 Money

Transmitters. The proposed changes implement provisions

of the CSBS Model Money Transmission Modernization Act

and are intended to further harmonize Maryland law with

other states and provide clarity and certainty regarding

the responsibilities of money transmitters and the rights of

consumers. The changes are anticipated to be effective in

FY 2024.

Commissioner Salazar and Director of Legislative Response at the bill signing

for HB379/SB 929; with Maryland’s Senate President, Governor Moore,

Secretary Wu, and Speaker of the House of Delegates.

Financial Regulation Annual Report 2023 Page 22 of 84

Updates on the

Office’s regulatory

and consumer-focused

activities over

the past fiscal year.

INDUSTRY SUPERVISION &

CONSUMER PROTECTION

Page 23 of 84

Financial Regulation Annual Report 2023

DEPOSITORY

The Office’s Depository Unit regulates and supervises a total of

33 Maryland state-chartered institutions as of the end of FY 2023.

Of those institutions, 22 are banks, seven are credit unions, and

four are non-depository trust companies. The Depository Unit also

supervised the American Share Insurance Corporation (ASI), an

Ohio-based, private provider of deposit insurance for credit unions.

The Depository Unit is overseen by the Assistant Commissioner for

Depository Supervision and as of the end of FY 2023, the Unit had

14 bank examiners on staff, of which five are examiners-in-charge.

Overall, Maryland-chartered financial institutions performed well in

FY 2023. Maryland’s banks and credit unions reported solid financial

condition, sound asset quality, ample capital augmentation, and

sufficient liquidity in the face of challenging market conditions.

In the Spring of 2023, liquidity became a focus for all regulatory

agencies because of two large regional bank failures in California

and New York. In response to the upheaval in the banking sector

precipitated by the failures, OFR risk-assessed its chartered

institutions and began focusing specifically on institutions’ immediate

liquidity sources, uninsured deposits exposure, non-bank financial

institution deposits concentrations, and investment portfolios. The

Office implemented daily liquidity monitoring of high-risk institutions,

as well as daily meetings with management of the institutions, and

it maintained regular contact with federal bank regulators. The

Federal Reserve created the Bank Term Funding Program (BTFP)

which offered loans of up to one year in length to banks and credit

unions pledging collateral eligible for purchase by the Federal

Reserve Banks in open market operations such as U.S. Treasuries,

U.S. agency securities, and U.S. agency mortgage-backed securities.

The BTFP served as an additional source of immediate liquidity

at reasonable terms. The Office contacted all Maryland-chartered

institutions and strongly encouraged them to establish a funding line

with the Federal Reserve discount window so they could have an

alternative funding source should the need arise. While Maryland’s

financial institutions did not face the liquidity pressures that affected

many of the nation’s financial institutions in the Spring, the majority

of the State’s banks and some credit unions took advantage of the

program and established BTFP funding lines, and some even used

their new funding line due to the attractive rates that were offered.

Overall, Maryland-chartered banks and credit unions strengthened

their liquidity positions and enhanced internal monitoring of liquidity

following the turmoil of Spring 2023.

Facing moderate loan demand throughout FY

2023, Maryland-chartered institutions were

fortunate to enjoy excess liquidity which was

primarily reallocated to securities investment

portfolios that generated higher returns given

the increasing rate environment. FY 2023 saw

Maryland state-chartered banks and credit

unions adopting the “current expected credit

losses” (CECL) methodology for estimating

their allowances for credit losses. The adoption

of CECL led to higher provision expenses

despite asset quality generally remaining good.

In April 2023, OFR gave a “Climate Change

Risks and Maryland Financial Institutions”

presentation to the management teams and

Boards of Directors of the State’s banks and

credit unions. The purpose of the presentation

was to provide guidance about OFR’s current

expectations regarding the management of the

various risks posed by climate change and on

the establishment of governance structures to

manage those risks. The Office’s climate change

presentation was well attended and banks

and credit unions were provided with learning

and discussion points regarding the effects

of climate change risk on Maryland financial

institutions. The Office continues to participate

in the CSBS District I Task Force, led by the

New York Department of Finance, on climate

change risk to community banks.

The Office continued its practice of issuing

regulatory advisories and guidance, responding

to inquiries from bankers, and monitoring loan

activity, concentrations, liquidity, information

technology and cybersecurity oversight, and

compliance with the Bank Secrecy Act/Anti-

Money Laundering.

Supervising Maryland State-Chartered Banks, Credit Unions, and Trust Companies

SUPERVISION

Page 24 of 84

Financial Regulation Annual Report 2023

DEPOSITORY

Bank Supervision

In FY 2023, only one Maryland-chartered bank was acquired by an

out-of-state bank. The reduction in the number of banks supervised

by OFR, from FY 2022 to FY 2023, is a considerable improvement

from the loss of five banks over FY 2021 to FY 2022. Management at

many Maryland-chartered banks remained focused on reevaluating

their resources, maintaining sound asset quality, and enhancing

earning performance during challenging economic times. Despite the

loss of one bank, total assets held by the remaining 22 banks under

OFR’s supervision grew by $2.5 billion, or 5.38%, from $47.1 billion to

$49.7 billion in FY 2023.

Aggregate capital in Maryland-chartered banks increased

approximately 6.10% from $5.1 billion to $5.4 billion over FY 2023.

The capital increased despite a slight decline in earnings caused

by an increase in provisions for loan and lease losses and reduced

noninterest income. Bank holding companies continued to be

successful in raising capital during FY 2023 and downstreamed equity

into their bank subsidiaries. The combined reported capital leverage

ratio of 10.77% represented a modest increase and can be generally

attributed to capital accretion outpacing asset growth. All Maryland-

chartered banks ended FY 2023 well-capitalized.

Even with the loss of one bank, Maryland-chartered banks’ aggregate

level of net loans and leases increased by 8.40%, from $33.8 billion

to $36.7 billion. Their level of investment securities also increased by

$403 million, or 5.38%, to $7.9 billion in FY 2023. Maryland-chartered

banks continued to serve their commercial customers with the Small

Business Administration’s Paycheck Protection Program (PPP) loans,

loan forgiveness, and loan modifications.

Asset quality performance indices for

Maryland-chartered banks were again positive

in FY 2023. With most institutions experiencing

loan growth, the level of non-performing assets

to total assets increased from the multi-year

low of 0.37% reported at FYE 2022 to a

higher level of 0.59% in FY 2023. That level

represents a continued historically low level

of non-performing assets, and of the non-

performing assets, other real estate owned

assets decreased significantly by 35.29% to

$11.0 million over the same period as banks

were able to liquidate the properties they

held in the face of the increasing interest rate

environment. Net charge-offs to total loans

and leases increased but ended the fiscal

year at a manageable, and also extremely low

level, of 0.12%, representing an increase over

the historically low 0.02% reported at FYE

2022. The overall level of banks’ allowance for

loan and lease losses increased by 24.46%, to

$450.8 million, which is commensurate with the

growth in loan portfolios and the adoption of

the CECL allowance calculation methodology.

Based upon these asset quality performance

indices, Maryland-chartered banks entered FY

2024 poised to focus on asset growth and net

operating income.

Supervising Maryland State-Chartered Banks, Credit Unions, and Trust Companies

SUPERVISION

Page 25 of 84

Financial Regulation Annual Report 2023

Toward the end of FY 2022, the Federal

Reserve’s Federal Open Market Committee

(FOMC) began raising interest rates in an effort

to curtail inflation. Maryland’s banks retained

good liquidity and they took advantage of the

higher interest rates by growing their investment

portfolios. The increased rates enabled Maryland

banks to generate increased interest income

on their loan portfolios and invested funds. The

FOMC continued its increasing interest rate

strategy throughout FY 2023 and into FY 2024.

For the State’s banks, earnings performance

experienced a continuing negative trend during

FY 2023. The banks’ average return on assets

(ROA) decreased from 1.49% ending FY 2022

to 1.35% at the end of FY 2023. As described

above, much of the decrease is attributed to

increased provisions for loan and lease losses

over FY 2022, which outweighed the increase

in the banks’ collective net interest margin.

Specifically, Maryland-chartered banks’ net

interest income was bolstered by the increasing

interest rate environment which improved their

collective net interest margin to 3.66% at the end

of FY 2023, from 3.53% at the end of FY 2022.

Safety and soundness examinations continued

to be full scope although examination activities

were modified in FY 2023 to accommodate

remotely conducted examinations and to

reduce the burden on Maryland bankers. During

examinations and off-site monitoring, OFR

assessed banks’ capital levels, asset quality

performance indices and trends, management

oversight, earnings levels and trends, liquidity

and funds management, sensitivity to interest

rate risk, and risk management practices, with

an emphasis on liquidity levels, liquidity risk

management, liquidity concentrations, uninsured

deposits and fundings sources, commercial

real estate lending, and lending concentrations.

Information technology, cybersecurity, and the

Bank Secrecy Act/Anti-Money Laundering

reviews and assessments also continued as

essential components of examinations.

Worthy of note is the fact that OFR issued

only one formal enforcement action due to

Bank Secrecy Act concerns during FY 2023.

To the extent that OFR had other concerns

with a small number of specific institutions, it

addressed them through enhanced regulatory

supervision and oversight, employing a variety

of means including regular teleconference calls,

visitations and targeted examinations, meetings

with management and Boards of Directors, off-

site reviews and monitoring, and informal enforcement actions.

As a result of their organic growth, Maryland has two state-chartered

banks each with over $10 billion in total assets and another four banks

each with assets over $1 billion. Banks over $10 billion in total assets

are required to comply with a variety of federal regulations that are

applicable to large, complex banking organizations. In addition, those

banks are subject to the examination and supervision authority of the

Consumer Financial Protection Bureau which examines institutions for

compliance with federal consumer financial laws.

Topics in the forefront of OFR’s work to continue into FY 2024 include

closely monitoring banks’ liquidity positions, asset quality, and servicing

practices related to information technology oversight, financial elder

abuse monitoring and prevention, and succession planning for both

management and Boards of Directors. Interest rate risk and liquidity risk

management will also continue to receive thorough attention throughout

FY 2024 as will compliance with the CECL reserve methodology and

the Bank Secrecy Act. Cannabis-related banking, which involves banking

related to marijuana and hemp products, gained attention in FY 2023,

and it is expected to remain a topic of interest as adult use marijuana

became legal in Maryland on July 1, 2023. The Office anticipates more

state-chartered banks will begin servicing cannabis-related businesses

in FY 2024.

Maryland-chartered banks have always had a significant impact on

the regional economy and they proved their significance during the

COVID-19 pandemic. The banking industry in Maryland continues to

serve its customers more efficiently; improve products, services, and

processes; and grow assets, and in some cases have partnered with

fintech companies to help in those efforts. Recognizing, however, that

there are gaps in the delivery and accessibility of banking services in

the State, and consistent with Governor Moore’s goal of establishing

Maryland as a state that leaves no one behind, in FY 2023 OFR began

planning implementation of the Access to Banking Act (House Bill 548)

in order to support and encourage industry efforts to ensure that banking

services and credit are offered equitably to all communities in the State.

The Office will remain in active dialogue with bank management teams

throughout the state and regularly seek out and participate in outreach

events sponsored by the Maryland Bankers Association, the Federal

Deposit Insurance Corporation, and Federal Reserve Bank. And, OFR

has and will continue to issue regulatory guidance when necessary, as

well as address institution-specific situations when they arise as part of

its mission to protect Marylanders through the operation of a modern

financial regulatory system that promotes respect for consumers,

safety and compliance, fair competition, responsible business

innovation, and a strong state economy.

Credit Union Supervision

The Office regulates and supervises seven Maryland-chartered credit

unions. Of the seven credit unions, the deposits of six are federally

insured through the National Credit Union Share Insurance Fund with

the deposits of the remaining credit union being privately insured by

ASI. Each of the credit unions received full scope safety and soundness

examinations during FY 2023. Those examinations were frequently

conducted via a hybrid approach with some work conducted remotely

and some work conducted onsite at the institution. As with the

Page 26 of 84

Financial Regulation Annual Report 2023

bank examinations, some examination activities were modified to

accommodate remote examination activity and to reduce the burden

on credit union management and staff. The Office supplemented

the examinations with quarterly, off-site monitoring and targeted

examinations as deemed necessary.

Overall, in FY 2023, the level of total assets held by Maryland-chartered

credit unions increased by 2.5% from $7.8 billion ending FY 2022 to

$8.0 billion ending FY 2023. Over the same period, total loan receivables

increased to $5.6 billion from $5.3 billion, investment and securities

declined from $1.7 billion to $1.4 billion, shares and deposits decreased

negligibly to $6.7 billion from $6.8 billion, and total capital increased

to $811.8 million from $757.5 million. Throughout FY 2023, Maryland-

chartered credit unions continued to serve their business members

with PPP loans, loan forgiveness, and loan modifications. Additionally,

the credit unions’ net worth increased from 9.70% of total assets to

10.21% of total assets, as capital accretion outpaced asset growth,

while their combined ROA increased considerably from 0.33% to 0.75%.

Much of the increase in their ROA was driven by the higher interest

rate environment that considerably improved their interest income.

Much as with the bank supervisory program, the focus of OFR’s work

in FY 2024 insofar as credit union supervision is concerned is to continue

close monitoring of credit unions’ liquidity, asset quality, cybersecurity

oversight, financial elder abuse monitoring and prevention, and

succession planning for management, directors, and Supervisory

Committee members. Interest rate risk, the CECL reserve methodology,

the Bank Secrecy Act/Anti-Money Laundering, and cannabis-related

banking, which includes banking related to marijuana and hemp

products, will also continue to receive attention throughout the 2024

fiscal year. Finally, OFR will be conducting follow-up on its 2023

climate change presentation and engaging with the state’s credit

unions to ensure they benefit from the Access to Banking Act

(House Bill 548) and that they participate in efforts to ensure that

financial services are offered equitably to all communities in the State.

Like Maryland’s banks, Maryland state-chartered credit unions also

benefited from a strong economy despite the Federal Reserve Bank

increasing interest rates, primarily in FY 2023 and continuing into FY

2024, in an effort to curtail inflation. Credit unions continued to serve

their membership and focused on increasing

membership and generating profitable assets.

The Office continues to be committed to

assisting credit union management with leading

their institutions while meeting the needs of

their membership. The Office has and will

continue to issue regulatory guidance when

necessary, and the Commissioner and staff

will remain in active dialogue with credit union

management and their Boards of Directors.

Also, OFR will continue to seek out and

participate in outreach events sponsored by

the MD|DC Credit Union Association and the

National Credit Union Administration (NCUA).

Non-Depository Trust Company

Supervision

Maryland’s four state-chartered non-depository

trust companies continued to perform effectively

throughout FY 2023. Trust company management

worked diligently to meet the needs of their

clients during uncertain domestic and global

times. Managed and non-managed assets

experienced strong growth with total assets-

under-management increasing to $596.2 billion

ending FY 2023 from $530.6 billion ending FY

2022. Trust companies generated net income

of $75.1 million during the first half of calendar

year 2023, which is up moderately from $73.9

million in net income generated during the first

half of calendar year 2022.

The trust companies anticipate additional growth

in FY 2024 and management will continue to

monitor volatility and economic conditions

in national and international bond and equity

markets, interest rates, and real estate markets.

Safety and soundness examinations of non-

depository trust companies are full scope

and have been conducted remotely since the

pandemic. The Office expects to conduct hybrid

examinations during FY 2024. Examiners’ focus

will remain on asset management, earnings,

capital, management, operations, internal

controls and audit, compliance, Bank Secrecy

Act/Anti-Money Laundering compliance,

information technology/cybersecurity

oversight, and succession planning.

Commissioner Salazaar and Secretary Wu at Financial Regulation

meeting April 2023.

Financial Regulation Annual Report 2023 Page 27 of 84

Page 28 of 84

Financial Regulation Annual Report 2023

DEPOSITORY

The Office began FY 2023 with regulatory responsibility for 23

banks with $47.142 billion in total assets, and ended FY 2023 with

responsibility for 22 banks with $49.677 billion in total assets, resulting

in an annual asset growth rate of 5.38%. While asset growth remained

steady over the past five years, the number of Maryland-chartered

banks has continued its decline. The 22 Maryland-chartered banks in

FY 2023 represent a 37.14% decrease from the 35 Maryland state-

chartered banks in FY 2018. The decrease from 23 to 22 Maryland-

chartered banks was due to the merger of a Maryland-chartered

bank into a bank chartered in West Virginia. Additionally, in FY 2023

OFR approved the merger of a Maryland-chartered bank into a

national bank headquartered in Maryland, however this merger did

not become effective until July 1, 2023. The completion of this merger

at the start of FY 2024 further reduces the number of Maryland-

chartered banks to 21.

While the number of Maryland-chartered banks continues to decrease,

the percentage of total bank assets held nationally as compared to

total bank assets held by Maryland-chartered banks continues to

increase, and bank consolidation has not adversely impacted the

asset growth for Maryland-chartered banks. Despite asset growth

remaining steady, OFR continues to monitor the possible effects that

consolidation and the resulting reduction in the number of Maryland-

chartered banks may have on local industry practices and control.

The Office also maintains regulatory responsibility for the seven

Maryland-chartered credit unions. Combined assets of these

seven institutions totaled $7.952 billion on June 30, 2023, which

represented annual asset growth of 1.78% for FY 2023. While total

asset growth slowed in FY 2023 for Maryland-chartered credit

unions, total asset growth over the past five years for Maryland-

chartered credit unions is 34.84%.

The consolidation and relocation of branches by Maryland-chartered

banks and credit unions remained robust in FY 2023. This trend

is a result of industry consolidation and a response to consumers

increasingly favoring the usage of electronic services to traditional

brick-and-mortar branch services. In FY 2023, a Maryland-chartered

credit union opened a new branch in Baltimore, Maryland, a Maryland-

chartered bank opened a new location in Cambridge, Maryland, and

(as of the date of this report) another Maryland-chartered bank will

be opening a new branch in Ocean City, Maryland, approved by

OFR in FY 2023.

As of the end of FY 2023, the State of

Maryland is served by 77 banks with 1,214

bank branches, down by 41 branches from

the previous year. While the number of bank

branches continues to decrease, JP Morgan

Chase Bank, a large national bank, notably

expanded from 26 to 32 branches in Maryland

in FY 2023. Out-of-state banks continue to

apply to open or relocate branches and offer

financial services in Maryland. Several branch

applications submitted by an out-of-state

bank and approved by OFR in FY 2023 are

scheduled to open in FY 2024.

Furthermore, as of the end of FY 2023, there

are forty branches operated by Maryland-

chartered banks in LMI neighborhoods in

Maryland and there are fourteen branches

operated by Maryland-chartered credit

unions in LMI neighborhoods. Of particular

note, on January 10, 2023, SECU, Maryland’s

largest credit union, earned the Low-Income

Designation (LID) from the NCUA. To qualify

as an LID credit union, a majority of SECU’s

membership met certain low-income thresholds.

The LID status comes with certain benefits

for SECU and its membership. These benefits

include an exception from the statutory cap

on member business lending, which may

expand access to capital for small businesses,

eligibility for grants and low-interest loans from

the Community Development Loan Fund, the

ability to accept non-member deposits, and the

authority to obtain supplemental capital. With

the addition of SECU’s LID status in 2023, five

of seven Maryland state-chartered credit unions

now possess a Low-Income Designation.

The Office maintains partnerships with

Maryland counterparts at the Office of the

Comptroller and the State Department of

Assessments and Taxation to improve the

Asset Growth and Consolidation Among Maryland State-Chartered Institutions Persist

CORPORATE ACTIVITIES

Page 29 of 84

Financial Regulation Annual Report 2023

experience of financial institutions doing business in Maryland.

Successful coordination with these agencies ensures that applications

are processed timely and records are accurate.

The number of merger applications also remained steady in FY 2023

as the industry continues to consolidate. OFR does not anticipate this

trend subsiding. As noted above, OFR approved two applications in

FY 2023 that resulted in the merger of a Maryland-chartered bank

into another institution. Provident State Bank, a Maryland-chartered

bank headquartered in Preston, Maryland, was acquired by Summit

Community Bank, a West Virginia-chartered bank headquartered in

Moorefield, WV. Additionally, Community Bank of the Chesapeake,

a Maryland-chartered bank headquartered in Waldorf, Maryland, was

acquired by Shore United Bank, a national bank headquartered in

Easton, Maryland. The merger of Community Bank of the Chesapeake

into Shore United Bank did not become effective until July 1, 2023.

The Office also approved the acquisition of Partners Bancorp, a

Maryland incorporated bank holding company for both The Bank of

Delmarva, a Delaware-chartered bank, and Virginia Partners Bank,

a Virginia-chartered bank, by LINKBANCORP, Inc., the Pennsylvania

incorporated bank holding company for LINKBANK, a Pennsylvania-

chartered bank. The merger did not impact the number of Maryland-

chartered banks, however both The Bank of Delmarva and Virginia

Partners Bank maintain branches in Maryland. And, while the merger

is still awaiting final federal regulatory approvals,

it is further illustration of the strong trend toward

consolidation within the industry.

Throughout FY 2023, OFR continued to intake,

review, and process applications from Maryland

state-chartered and out-of-state institutions

needing OFR’s approval to effectuate certain

changes to these institutions’ corporate

operations. Among these submissions, OFR

processed fourteen representation as a bank

or trust company applications from out-of-state

institutions; four applications to amend the

bylaws of a Maryland-chartered institution; two

Maryland Affordable Housing Trust applications,

and one application submitted by a Maryland-

chartered bank (BayVanguard Bank) to convert

from a savings bank to a commercial bank.

For additional facts and figures, see Appendix

A: State-Chartered and Depository Institutions

on page 50.

Page 30 of 84

Financial Regulation Annual Report 2023

The Licensing Unit is responsible for the licensing and registration of financial service providers under OFR’s jurisdiction.

This includes the processing of original, renewal, and relicensing of applications. The license categories under OFR’s

jurisdiction include mortgage lenders, brokers, and servicers; money transmitters; check cashers; debt management

service providers; debt settlement service providers; collection agencies; consumer lenders; installment lenders; sales

finance companies; credit service businesses; and consumer credit reporting agencies. The Unit also licenses individuals

as mortgage loan originators.

By the end of FY 2023, the Unit issued and managed 20,313

licenses to individuals and businesses, representing a

decline of 18% from the previous year. A large portion of the decline was due to the economic environment in which

rising interest rates saw the mortgage industry experiencing a slowdown late in FY 2022 continuing into FY 2023.

As a result, the Unit saw a significant reduction in the number of licensed mortgage lenders and loan originators. The

tightening interest rates did not significantly impact the licensure of other industry participants as there was a significant

increase in the non-mortgage space. In particular, sales finance companies in Maryland increased from 843 in FY 2022

licensed entities to 1,060 in FY 2023.

When reviewing new license applications, the Unit ascertains whether the applicant may have improperly engaged

in licensable activities prior to the application. During FY 2023, the Unit collected $40,300 in penalties due to prior

unlicensed activity.

Streamlining the Licensing Process

The Unit furthered its efforts to streamline licensing processes in FY 2023. During its 2023 session, Maryland’s General

Assembly passed, and Governor Wes Moore signed, House Bill 686. The new law, which takes effect in FY 2024, makes

significant changes to the Maryland statutes governing the licensure of financial service providers. Starting July 1, 2023

OFR will cease issuing, maintaining, and renewing individual licenses for branch locations, and there will be no license fee

associated with those locations. This change will apply to all business types licensed by OFR or by the State Collection

Agency Licensing Board. Each business will need only a single Maryland license for a given business activity as that

license will serve for all locations properly disclosed to OFR at which the licensee conducts business.

In addition to the elimination of branch licensing, the new law allows OFR to levy a variable, annual assessment

proportionate to each business. When determining the amount of an assessment, OFR may utilize a number of factors,

including a licensee’s volume of business conducted in Maryland and the risks posed by its operations. The new law does

not impact other requirements for licensure, such as bond requirements and the disclosure of all branch locations and

trade names.

This number refers to licenses in active status.

Opening Doors for Business

LICENSING

Page 31 of 84

Financial Regulation Annual Report 2023

License Category

New Licensees

FY 2023

Total Licensees

FY 2023

New Licensees

FY 2022

Total Licensees

FY 2022

Check Casher 33 246 64 247

Collection Agency 136 1,561 107 1,547

Consumer Loan 31 234 25 223

Credit Service Business 19 70 22 62

Debt Management 3 25 0 16

Installment Loan 13 186 22 182

Money Transmitter 62 274 53 278

Mortgage Lender 832 3257 917 3,531

Mortgage Loan Originator 2,721 13,294 6,359 17,801

Registered Exempt Mortgage Lender 3 17 2 7

Sales Finance 223 1060 148 843

TOTAL 4,076 20,224 7,719 24,737

New Business Licensees and Total Business Licensees, by Category

Fiscal Years 2023 and 2022

Registrant Category

New Registrants

FY 2023

Total Registrants

FY 2023

New Registrants

FY 2022

Total Registrants

FY 2022

Credit Reporting Agencies 7 55 10 75

Debt Settlement Services 9 38 5 48

TOTAL 16 93 15 123

New Business Registrants and Total Business Registrants, by Category

Fiscal Years 2023 and 2022

The Unit continued its participation in the Multistate Money Services Businesses Licensing Agreement (MMLA) which

was established to create a more efficient money service business licensing process among state regulators. The MMLA

allows applicants to apply for licensure in multiple states without submitting multiple applications. Rather, one lead state

reviews the core application requirements and the other (non-lead) states will rely on the lead state’s review during

their own approval process. The other states only need to review their own state-specific requirements, if any. Utilizing

the MMLA helps make the licensing process more consistent and efficient for all parties. The Office’s Licensing Unit

processed three multistate applications as the lead state in FY 2023.

Page 32 of 84

Financial Regulation Annual Report 2023

FINANCIAL SERVICES

The Financial Services Licensing and

Supervision Unit changed its name in FY 2023

from “Non-Depository Supervision” to better

reflect the activities of the Unit and the types

of institutions it supervises. The Unit supervises

the individuals and businesses that are licensed

or registered to provide credit and other

financial services to Maryland consumers. These

financial service providers include mortgage

lenders, brokers, servicers, and originators,

money transmitters, debt management services

providers, debt settlement services providers,

collection agencies, credit reporting agencies,

check cashers, consumer lenders, sales

finance companies, credit service businesses,

and installment loan companies. In FY 2023,

the Unit had regulatory oversight of more

than 15,700 individuals and more than 3,800

businesses.

The Unit maintains a regular examination

program for mortgage service providers,

money transmitters, and debt management

service providers. During examinations, Unit

staff members (“financial examiners”) assess

the operations of these licensees to ensure

that they are complying with applicable

laws and regulations and operating in a

safe and sound manner, minimizing risks to

Maryland consumers. Violations identified by

examiners may result in restitution to Maryland

consumers or in civil penalties. In FY 2023,

the Unit assessed approximately $86,500 in

penalties relating to violations identified during

examinations.

As part of the Office’s efforts to work

cooperatively with fellow regulators in other

states, share information, and leverage

each other’s resources, the Unit continued

to conduct examinations through the State

Examination System (SES) during FY 2023. The

SES is a comprehensive system for examination

and regulatory investigation management that:

simplifies communication between regulators

and licensees during examinations or investigations, allows for customized

information requests from regulators to licensees, provides for secure

transmission of electronic documents from licensees to regulators,

allows for storage of examination and investigative records, and aids in

the sharing of examinations and regulatory investigations among states.

During FY 2023, the Unit’s Assistant Director of Mortgage Supervision

served on a working group which developed a proposal to streamline

the conduct of examinations through SES by eliminating duplicative or

extraneous “information requests” sent through the system to businesses

being examined.

The Unit continued to provide representation on various national boards

and committees during FY 2023. The Unit is represented on the Multistate

Mortgage Committee, the Board of Directors of the American Association

of Residential Mortgage Regulators, the Education Steering Committee

of the Money Transmitter Regulators Association, and the NMLS Money

Services Business Call Report Subcommittee.

Mortgage Supervision

Mortgage Supervision supervises the business activities of licensed

mortgage brokers, lenders, servicers, and loan originators conducting

business in Maryland. Companies that maintain a Maryland Mortgage

Lender License are licensed to conduct mortgage brokering, lending, and

servicing activities with respect to Maryland residential mortgage loans.

Individuals that maintain a Maryland Mortgage Loan Originator License

are employees of a mortgage lender licensee and are licensed to take

mortgage loan applications from Maryland residents and negotiate loan

terms.

Mortgage Supervision is responsible for conducting examinations of

licensed mortgage brokers, lenders, servicers, and loan originators.

Through its examinations, Mortgage Supervision ensures that licensees

comply with applicable federal and state laws and regulations in providing

financial services to Maryland residents.

A statutory enactment during FY 2021 changed the examination

scheduling requirement for each licensee under the responsibility of

Mortgage Supervision from once during any 36-month period to once

during any 60-month period. Maryland law retained the requirement

that new licensees be examined within 18 months of initial licensure. This

change was made to provide Unit staff with greater flexibility to conduct

risk-based examinations. A risk-based approach allows OFR to examine

well-managed, compliant businesses less frequently than those deemed

risky, so the examination staff can place greater emphasis and resources

on businesses that pose a heightened risk to Maryland consumers.

Supervising Mortgage, Consumer Credit, and Money Services Businesses

SUPERVISION

Page 33 of 84

Financial Regulation Annual Report 2023

In FY 2023, Mortgage Supervision commenced examinations

of 253 licensed businesses and completed examinations of 138

licensed entities (some of the completed examinations having

commenced prior to the start of the fiscal year). Mortgage

Supervision assessed $208,375 in monetary recoveries

for consumers from violations identified during mortgage

examinations.

Mortgage Supervision staff continues to take an active role

in multistate examinations of mortgage lenders, brokers,

and servicers. These multistate examinations benefit both

consumers and industry – states benefit as the use of a large,

multistate team of examiners results in a more robust, more

detailed examination than a single state could perform on its

own. Businesses also benefit in their ability to manage one

comprehensive examination, rather than a series of individual

state examinations, thereby reducing regulatory burden. In FY

2023, the Unit participated in four joint examinations with other

states under the auspices of AARMR/CSBS Multistate Mortgage

Committee (MMC). As of the end of FY 2023, two of these

examinations are still in progress.

Employees of the Unit continue to maintain their professional

competence through continuing education. During FY 2023,

Mortgage Supervision staff members attended training on

subjects including corporate governance and cybersecurity risks.

Staff members were also trained on a new baseline cybersecurity

examination program. Mortgage Supervision’s more tenured

examiners continue to maintain Certified Mortgage Examiner

or Certified Senior Mortgage Examiner certifications issued

by CSBS. In addition, three examiners hold the Certified Fraud

Examiner designation and attended training sponsored by the

Association of Certified Fraud Examiners.

In FY 2023, Mortgage Supervision continued to

have an employee appointee on the MMC, and

had an employee re-elected to another term as

an officer and member of the Board of Directors

of AARMR. This representation, along with the

continued participation in MMC examinations,

ensures that Mortgage Supervision staff have an

active role within the state regulatory community

and provides meaningful input into coordinated

mortgage supervision nationwide.

Money Services and Consumer

Credit Supervision

Money transmitters, also known as remittance

companies, are financial organizations that specialize

in providing fast and reliable cross-border money

transfer services. They offer a range of services,

such as receiving and transmitting funds, issuing

money orders and travelers’ checks, and providing

prepaid stored value cards. In addition, many

money transmitters offer innovative technologies

such as mobile apps and online platforms to

enhance consumer access to financial services.

Looking ahead, the Office plans to sustain its

emphasis on oversight of money transmitters.

This will involve ongoing collaboration with

industry stakeholders, regulatory bodies, and

other parties to ensure that the industry remains

secure, transparent, and compliant with established

regulations. During FY 2023, the money

Page 34 of 84

Financial Regulation Annual Report 2023

transmission industry continued to witness a swift pace of technological

innovation, coupled with an increase in the number of new business

models that involved the transfer of virtual currencies. Some of

these technological innovations include mobile money services,

neobanks, and payment gateways. Recognizing the evolving risks

that come with innovation in this space, particularly to Maryland

consumers and the Maryland financial services industry, the Office

continues to strengthen its oversight of money transmitters. For

example, in FY 2023, the Office chartered the Innovation and

Emerging Issues Committee. The main responsibility of this

committee is to support innovation in the financial services sector

under the jurisdiction of the Commissioner and ensure the

regulatory and supervisory mandates of OFR are addressed

on an intra-agency basis.

Money transmitters fall under the classification of money service

businesses as per federal law. As such, they are required to comply

with the regulations governing Anti-Money Laundering and the Bank

Secrecy Act. To ensure consistency with these regulations, Money

Services and Consumer Credit Supervision (MSCCS) examiners

participate in programs with the U.S. Internal Revenue Service and

the U.S. Treasury Department’s Financial Crimes Enforcement

Network. The primary objective of these programs is to prevent

money laundering and promote financial transparency.

During FY 2023, the MSCCS Unit conducted examinations of

61 licensed entities. Out of those, 22 were full examinations, while

39 were desk reviews. In desk reviews, staff members review

examination reports from other states’ regulators and supplement

that information with a review for compliance with Maryland laws

and regulations. This risk-based approach to examinations allows the

Office to examine licensees in an efficient and timely manner while

still maintaining minimum standards and the Office’s commitment to

protecting consumers. The 61 entities that underwent examination

offer services through a total of 734 authorized delegates located

throughout the State.

During FY 2023, the MSCCS Unit participated in 22 multistate

examinations, with 16 of these examinations being conducted under

the “One Company, One Exam” program. This initiative streamlines

the examination process for large money transmitters that operate in

at least 40 states. Under this program, these entities are subjected to

only one examination per year, which is conducted jointly by multiple

state regulators. States that do not participate in the examination

process are required to either accept the report of the joint examination

or abstain from examining the company for at least 12 months. This

approach aims to reduce the regulatory burden on the company and

promote a cooperative network approach to regulation by the states.

The employees working in the MSCCS Unit

ensure that they keep themselves updated with

the latest industry developments and receive

regular training to maintain their professional

development. Last fall, the examiners attended

the Money Transmitter Regulators Association’s

(MTRA) Intermediate and Advanced Examiner

Schools, and the MSCCS staff also attended

other relevant training sessions. MCCCS’s

senior examiners hold the Certified Money

Service Examiners certification issued by

CSBS. Furthermore, with the advancements

in cryptocurrency, in FY 2023 the MSCCS

Unit continued to deepen its expertise in this

evolving area. For example, the Unit received

training on the fundamentals of cryptocurrency,

including attending a “Crypto Risk and

Regulations” course offered by CSBS and

obtaining the “Cryptocurrency Fundamentals

Certification” offered by Chainalysis. Staff

also attended the Cybersecurity Audit School

offered by CSBS to enhance their skills and

knowledge in IT and cybersecurity.

In FY 2023, the MSCCS Unit had staff

representing OFR on two key committees:

the Education Steering Committee of the

MTRA, which is responsible for establishing

national standards for examiner education;

and the Money Service Business Call Report

Sub Committee, a State Regulatory Registry

Committee, which sets the standards for

money service business financial reporting

to the National Multistate Licensing System

(NMLS). In addition, MSCCS staff participated

in the pilot program for the State Examination

System Training for MSB Examiners to provide

feedback on the functionality of the multistate

system. The participation of MSCCS staff

on these committees and the pilot program

highlights OFR’s and the Unit’s support of and

commitment to a strong and coordinated state

regulatory system. It also demonstrates the

Unit’s dedication to learning and development

by staying abreast of national standards and

best practices in the field of financial regulation

and examination.

Page 35 of 84

Financial Regulation Annual Report 2023

CONSUMER

The Consumer Services Unit (CSU) investigates complaints from

Maryland consumers about financial service providers that are

licensed, registered, or chartered in Maryland or that are engaged in

financial service activities regulated by OFR. Consumer complaints

play a vital role in helping OFR enforce consumer protection laws and

monitor trends in the financial services industry. In FY 2023, CSU

received 1,317 complaints, a 19% increase over the prior fiscal year.

Complaint investigations are typically resolved within 60 days.

In FY 2023, the average amount of time for complaint resolution

ranged from 31 to 58 days (as calculated monthly). When determining

an appropriate resolution to a complaint, CSU considers issues

of harm or potential harm to the general public as well as specific

to the individual complainant. If the investigation reveals that

violations of law have occurred, further action may be taken by

OFR, including requiring the reimbursement of fees, interest,

or other consumer restitution. In FY 2023, CSU was successful

in recovering restitution payments of $125,425 for Maryland

consumers through its investigative and complaint resolution

activity. Over the last five fiscal years, CSU has recovered a

total of $846,573 for Maryland consumers.

The Unit assists consumers with a range of complaint issues involving the financial service industries and activities regulated

by OFR, and responds to consumer inquiries over the phone and via email. The Unit also supports the Maryland Student

Loan Ombudsman with student loan complaint intake and resolution. Consistent with trends from prior fiscal years, the

largest proportion of consumer complaints received by CSU involved issues related to mortgages and foreclosures,

representing approximately 21% of all complaints in FY 2023.

From FY 2022 to FY 2023, there was a 47% increase in complaints involving Maryland banks and credit unions, and a 62%

increase in non-jurisdictional complaints. The subjects of “non-jurisdictional complaints’’ are national banks and federal

credit unions (which are supervised by a federal agency) or out-of-state banks and credit unions (which are supervised by

the financial regulator in the state where the institution is chartered). The significant share of non-jurisdictional complaints

in FY 2022 was attributed to changes in OFR’s electronic consumer complaint form. The increasing share of consumer

complaints in FY 2023 that are categorized as non-jurisdictional could be a result of national or state economic trends, such

as the growing number of banks and credit unions operating in Maryland that are not chartered by OFR. Further analysis

will be done to understand this trend in the complaint data.

The Unit maintains strong working relationships with other state and federal regulatory agencies, including the U.S.

Consumer Financial Protection Bureau and the Office of the Comptroller of the Currency (OCC). With these relationships,

CSU is able to send non-jurisdictional complaints directly to the proper state or federal agency, providing consumers

with a seamless transition. The Unit coordinates access to the OCC’s electronic portal for the efficient and expeditious

referral of complaints involving national banks not under OFR’s jurisdiction. The portal allows CSU to send and confirm

the receipt of complaints directly with the OCC, thereby eliminating the need to transfer complaints by mail.

The Unit continues to utilize SES for complaint case management, which is the same system utilized by OFR’s Financial

Services Supervision Unit for examinations of mortgage and non-mortgage licensees. The SES was developed by the

State Regulatory Registry, the CSBS subsidiary that operates the NMLS. The Assistant Director of CSU remains a member

of the SES Consumer Complaints Subcommittee and continues to monitor for any new features or improvements to the

system, however, CSBS has stated that it’s focusing its efforts on NMLS upgrades in the near future.

Protecting and Supporting Maryland Consumers

Complaint Category Number

Mortgage 283

Consumer Loans 118

Collection Agencies 136

Credit Reporting Company 98

Maryland Banks & Credit Unions 132

Miscellaneous 88

Student Loans 49

Non-Jurisdictional* 413

Total Annual Complaints 1,317

* Complaints received against national banks, federal

thrifts, federal credit unions and out-of-state banks.

Consumer Complaints: FY 2023 Summary

SERVICES

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Financial Regulation Annual Report 2023

The Enforcement Unit is the investigatory and enforcement arm of

the Office. The Unit investigates fraud-related issues and conducts

special investigations involving banks, credit unions, licensed financial

service providers and unlicensed business entities, with the goal

of uncovering and addressing violations of law, predatory and illicit

behavior, improper business practices, unlicensed financial services

activity and other misconduct by regulated entities subject to the

jurisdiction of OFR. The Unit is also tasked with coordinating the

enforcement activities brought by the Commissioner, including

determining whether action is warranted, referring matters to litigation

counsel, and managing the process when action may be taken.

Enhancing Operational Processes

In FY 2023, the Enforcement Unit continued to identify areas where

it could improve its operations to more efficiently and effectively

deploy resources to meet OFR’s mission of protecting consumers

and regulating the financial services industry in Maryland. To that

end it continued evaluating, improving, and streamlining systems

used as a part of the investigative process and refining the Unit’s

policies and procedures. The Unit’s onboarding and training processes

were reevaluated to improve effectiveness and efficiencies as new

staff was hired. An emphasis was placed on offering continuing

education courses to fraud examiners to improve their existing skill

sets and to develop in new areas. Members of the Unit traveled to

a multi-day training conference to learn more about the emerging

risks and regulatory issues surrounding cryptocurrencies and how to

investigate virtual currency. Examiners and Unit leadership enhanced

their financial fraud investigation skills by taking part in an in-depth

training program covering financial transactions, fraud schemes, law,

investigation, and fraud prevention and deterrence.

Collaborations with Industry Partners

Enforcement Unit staff collaborated with multiple industry

partners throughout FY 2023. The Unit worked with CSBS via

the Enforcement Protocol Workgroup to develop processes and

standards for multistate enforcement actions. The purpose of this

workgroup was to establish governance and a formalized framework

for the administration of multistate enforcement matters brought

by state regulators, from identification to closure. The Director

of Enforcement participated in the Non-Depository Supervisory

Committee Multistate Enforcement Protocol Workgroup which met

for eight drafting sessions and delivered an initial document for

review by the Committee in May 2023. The Protocol itself establishes

an important milestone in multistate supervision achieved through

engagement with the State of Maryland and

fellow state regulators. These efforts are an

achievement for the state system, particularly

for midsize and small states, and will aid in

a more cohesive approach to networked

enforcement investigations and actions.

In addition, the Director of Enforcement

collaborated with the Consumer Financial

Protection Bureau, Maryland Office of the

Attorney General - Consumer Protection

Division, and the Federal Housing Finance

Agency throughout the fiscal year to exchange

ideas, discuss new cases and novel schemes,

emerging enforcement areas and technology

needs.

Development of Enforcement

Priorities

The Unit also developed its Enforcement

Priorities to be implemented in FY 2024. These

priorities identify areas posing the greatest risk

of financial harm to Maryland consumers and to

the integrity of the financial services industry

in Maryland, articulate OFR’s intent to industry

and our stakeholders, and indicate where OFR

will direct resources and expertise.

The Enforcement Priorities are:

• New or innovative products or services.

Innovation in financial services can expand

financial options and improve lives.

However, it can also lead to significant

harm for consumers, particularly financially

vulnerable consumers. The Office will use

its enforcement resources to pursue matters

involving innovative or new products or

services that create significant risk of

consumer harm, or that involve a violation

of consumer rights laws in Maryland. The

Office will focus on areas that provide an

opportunity to clarify or affirm its position

concerning the application of existing law to

the product or service.

Ensuring Industry Accountability through Investigation and Action

ENFORCEMENT

• Bank-fintech partnerships. The Office

will scrutinize and pursue bank-fintech

partnerships that offer products or services

that violate Maryland’s usury laws.

• Recidivism. The Office will investigate and

pursue cases involving repeat offenders

in certain areas. Specifically, companies

or individuals who violate an Order issued

by OFR or a Court in connection with an

OFR investigation or enforcement action,

or companies or individuals who have

committed the same or similar violations in

other jurisdictions. The Office will prioritize

pursuit of cases of recidivism involving the

following businesses and activities:

» Mortgage companies

» Money service businesses

» Unlicensed consumer loans

» Debt collection and debt servicing

» Fraud schemes or predatory lending

• Systemic issues resulting in widespread

consumer harm. The Office will pursue

actions against companies or individuals if

an investigation suggests that a significant

number of Maryland consumers were, or

could have been, impacted by ongoing

or repeated patterns or practice of

misconduct.

• Redlining and discrimination in lending.

Enforcement of fair lending and anti-

discrimination laws is a priority for OFR.

This priority demonstrates our commitment

to ensuring equal access to lending

opportunities, particularly mortgage

lending, for everyone regardless of race or

national origin. The Office will investigate

and focus resources on complaints alleging

redlining and violations of the Equal Credit

Opportunity Act, Fair Housing Act, and

other anti-discrimination laws.

The Office will review its list of Enforcement Priorities at least annually

and may make changes to respond to new or emerging risks to

Maryland consumers or regulated industries.

Foreclosure Prevention: Enforcing Servicer

Participation in the Maryland Homeowner

Assistance Fund

The Homeowner Assistance Fund (HAF) authorized by the American

Rescue Plan Act, provided $9.961 billion to support homeowners

facing financial hardship associated with COVID-19. The HAF funds

were distributed to states, U.S. Territories, and Indian Tribes. Funds

from HAF may be used for assistance with mortgage payments,

homeowner’s insurance, utility payments, and other specified

purposes. The State of Maryland received HAF funds via the

Maryland Department of Housing and Community Development

(DHCD) in the amount of $248,588,848.

The Enforcement Unit supported OFR’s efforts to improve

communications with the Department, identify potential opportunities

to make the HAF program run smoothly, and benefit the homeowners

it intended to reach. Specifically, the Unit’s examiners contacted

twenty-two servicers to hear about their experiences with HAF

participation. The goal was to obtain more information about what

was causing delays in processing homeowner applications and

breakdowns in communications. While working on their existing

investigations, Unit staff researched the HAF program and conducted

outreach and soft investigations in an effort to inform the agency

about the rollout of the program, support the Consumer Services

Unit, understand potential challenges facing industry and assist

impacted Maryland consumers.

Significant Investigations and Enforcement

Activities

In FY 2023, OFR served as lead investigator in a multistate

examination involving ACI WorldWide, Inc., regarding the company’s

transmission of more than 1.4 million erroneous mortgage payment

debit instructions totaling more than $2.3 billion and affecting more

than 478,00 consumers nationwide and approximately 14,000

consumers in Maryland. Office staff was also part of the team

negotiating the historic settlement with ACI. The settlement, which

includes states’ attorneys generals as well as financial regulatory

agencies, was finalized in FY 2024.

Financial Regulation Annual Report 2023 Page 37 of 84

Page 38 of 84

Financial Regulation Annual Report 2023

5.6%

1.9%

3.7%

Mortgage (24)

Debt Relief Services (10)

Loans (10)

Credit Reporting Agency (3)

Credit Services Business (2)

Non-Jurisdictional (2)

State-Chartered Credit Union (2)

Money Services Business (1)

FY23 New Enforcement Investigations

(52 Total New Investigations)

The Office also participated in a multistate investigation against a

mortgage loan servicer concerning allegations that three affiliated

companies were involved in a major personal identifiable information

data breach. The entities reported that approximately 5.8 million

consumers, including 124,000 Maryland consumers, were impacted.

The entities failed to notify OFR of this alleged data breach as required

by regulation. The Office contributed a cyber auditor to the multistate

examination to determine the scope and impact of the data breach.

In July 2022, OFR entered into a consent order with a credit service

business Phantom Ventures, Inc. (“Phantom”) for unlawful practices

associated with mortgage loan modification consulting services

offered in Maryland. The consent order cited Phantom’s violations

of the Protection of Homeowners in Foreclosure Act for collecting

compensation from consumers prior to fully performing contracted

services in violation of Real Property (RP) § 7-307(2), failing to provide

Notice of Rescission to consumers in violation of RP § 7-305, and for

failing to provide a signed and dated copy of the written agreement to

consumers in violation of RP § 7-306; as well as violating the Maryland

Mortgage Assistance Relief Services Act (MARS) for requesting and/

or receiving payment of any fee or consideration prior to consumers

obtaining a mortgage loan modification in violation of RP § 7-502

& CFR 1015.5(a), failing to provide proper disclosures in commercial

communications with consumers in violation of RP § 7-502 (MARS)

& CFR 1015.4(b), failing to provide proper disclosures when advising

consumers to stop making mortgage payments in violation of RP § 7-502

& CFR 1015.4(c), and for failing to investigate

consumer complaints in violation of RP §

7-502 & CFR 1015.9(b)(iii)(2). Pursuant to the

settlement, Phantom agreed to cease and

desist from originating, making or otherwise

offering mortgage assistance relief services

and/or foreclosure consulting activities with

Maryland consumers, either directly or indirectly

through a third-party, pay a penalty of $10,000

to the Commissioner, and make payments to

the 15 consumers identified by OFR during its

investigation in the cumulative amount

of $27,840.

In the matter of Bangladesh Christian

Cooperative Society, LLC (BCCS), OFR issued

a Summary Order to Cease and Desist and

Order to Produce after finding grounds to allege

BCCS’s activities constituted the unauthorized

operations of a credit union in violation of

Maryland law and unlicensed lending to Maryland

consumers in violation of Maryland Consumer

Lending Laws. The Office found that it was in the

public interest that BCCS cease and desist from

continuing operation as a credit union and making

loans or otherwise engaging in lending activities

with Maryland consumers. The Office prohibited

BCCS from making loans or advances of money

or credit of any nature whatsoever, renewing

any loans, modifying the terms of any loans,

collecting payments on or otherwise servicing

loans, discharging loans, selling, transferring or

assigning any loans, taking possession of any

collateral associated with any loans and making

any payments to vendors, salaries, dividends

and interest.

Type Amount

Consumer Restitution (assessed) $27,840

Civil Penalties (collected) $40,162

Total $68,002

Enforcement: FY 2023 Monetary Recoveries

Page 39 of 84

Financial Regulation Annual Report 2023

Due to a coding error in case management software, the number of new investigations reported in fiscal years 2020

through 2022 were inaccurate. The Office is providing revised pie charts for those three fiscal years below.

3.3%

Mortgage (40)

Loans (24)

Debt Relief Services (12)

Credit Reporting Agency (3)

Credit Services Business (3)

Money Services Business (3)

Non-Jurisdictional (3)

State-Chartered Credit Union (3)

FY22 New Enforcement Investigations

(91 Total New Investigations)

2.9%

5.9%

2.9%

Mortgage (20)

Loans (6)

Debt Relief Services (4)

Money Services Business (2)

State-Chartered Bank (1)

Student Loan (1)

FY21 New Enforcement Investigations

(34 Total New Investigations)

2.3%

Mor tgage (15)

Credit Services Business (8)

Debt Relief Services (8)

Student Loan (6)

Loans (5)

Money Services Business (1)

State-Chartered Bank (1)

FY20 New Enforcement Investigations

(44 Total New Investigations)

Financial Regulation Annual Report 2023 Page 40 of 84

Page 41 of 84

Financial Regulation Annual Report 2023

FORECLOSURE SYSTEMS

Three residential foreclosure-related reporting mandates fall under the authority of the Office: Notices of Intent to

Foreclose (NOI), Notices of Foreclosure (NOF), and Foreclosed Property Registrations (FPR). All three notices/

registrations must be submitted to OFR electronically through a secure online interface.

Office staff are responsible for oversight of the reporting process and, with support from the Maryland Department of

Labor’s Office of Information Technology, the development and maintenance of the electronic system and databases.

An NOI is mailed by the secured party of the mortgage in default to the borrower at least 45 days prior to the

foreclosure action being filed in court, and a copy of the NOI is required to be electronically submitted to OFR. The

NOI provides crucial information about the mortgage and instructions to the borrower for pursuing an alternative to

foreclosure. Copies of all NOIs must be submitted to OFR through the electronic system. The data received by OFR is

used to facilitate its various supervisory responsibilities and outreach activities.

An NOF is an electronic registration submitted to OFR within seven days of the filing of the Order to Docket or Complaint

to Foreclose (the initial court filing that starts the legal foreclosure process) by the party authorized to foreclose. The

NOF provides ownership information about properties in the beginning stages of the foreclosure process and is used

by Maryland county and municipal officials to better facilitate code enforcement, nuisance abatement, law enforcement,

public health, and other related activities that fall under the purview of local governments.

An FPR is an electronic registration submitted to OFR within 30 days of the foreclosure sale by the party purchasing the

property. The FPR provides ownership information about foreclosed properties near the end of the foreclosure process.

Like the NOF, the FPR is used by Maryland county and municipal officials to better facilitate code enforcement, nuisance

abatement, law enforcement, public health, and other related activities that fall under the purview of local governments.

In April 2020, in response to the COVID-19 pandemic, OFR closed the electronic NOI system in accordance with

an executive order. The system remained closed through FY 2021. The closure of the NOI system virtually halted

the initiation of residential foreclosures in Maryland. With the reopening of the NOI system at the start of FY 2022,

foreclosure activity resumed, and during FY 2023 NOIs returned to pre-pandemic levels. However, NOFs and FPRs

remained below pre-pandemic levels throughout FY 2023.

In FY 2023, OFR began posting on the Maryland Open Data Portal the number of foreclosure notices and registrations

received by the Office. The numbers of NOIs, NOFs and FPRs are updated monthly and aggregated by Maryland county.

An additional posting of the number of NOIs aggregated by zip code is also updated monthly. For direct links to the

Open Data Portal, see the Foreclosure Data Tracker page on OFR’s website at labor.maryland.gov/finance/consumers/

frforeclosuredatatracker.shtml.

Oversight of the Electronic Reporting System for Foreclosure Notices and Registrations

ADMINISTRATION

Page 42 of 84

Financial Regulation Annual Report 2023

FORECLOSURE SYSTEMS

ADMINISTRATION

Oversight of the Electronic Reporting System for Foreclosure Notices and Registrations

Notices of Intent to Foreclose

Received per Fiscal Year

Notices of Foreclosure (NOFs) and Foreclosed Property Registrations (FPRs)

Received per Fiscal Year*

* NOF requirement went into effect October 2018.

Page 43 of 84

Financial Regulation Annual Report 2023

Foreclosure Systems: FY 2023 Summary Table

Notice of Intent

to Foreclose (NOI)

Notice of

Foreclosure (NOF)

Foreclosed Property

Registration (FPR)

Number Received

by OFR

64,989 10,551 2,195

Stage of

Foreclosure

Mortgage or other

contractual default

Foreclosure action filed

in court

Foreclosure

sale/auction

Reporting

Requirement

After the first missed payment

and no less than 45 days prior

to foreclosure action filing

Within 7 days

of filing

Within 30 days of sale (initial

FPR) and within 30 days of

deed recordation (final FPR)

Person

Submitting

Secured party

(or their agent)

Person authorized to make

the foreclosure sale

(or their agent)

Foreclosure sale purchaser

(or their agent)

Requirement

Effective Date

January 2011 (for electronic

submission)

October 2018 October 2012

Primary User

and Purpose

Office of

Financial Regulation –

supervision and outreach

Maryland local or state

governments – nuisance

abatement and other

related activities

Maryland local or state

governments – nuisance

abatement and other

related activities

Financial Regulation Annual Report 2023 Page 44 of 84

Page 45 of 84

Financial Regulation Annual Report 2023

STATE COLLECTION AGENCY

Regulating the Debt Collection Industry in Maryland

The State Collection Agency Licensing Board was established by the Maryland General Assembly in 1977 and resides

within the Office. The Board has statutory responsibility for the licensing of consumer debt collection agencies operating

in Maryland. The Governor, with the consent of the Senate, appoints two consumer representatives and two industry

representatives to the Board. The Commissioner of Financial Regulation serves as the Board’s Chairman.

Office personnel provide administrative and technical support for the Board, managing functions such as the processing

of license applications, the investigation of consumer complaints, enforcement actions, and outreach activity. Staff

members provide regular reports to the Board on these and other matters. Legal counsel is provided to the Board by the

Assistant Attorneys General assigned to the Office.

During FY 2023, the Board met monthly to make licensing decisions and address emerging issues pertinent to its

mission and responsibilities. During FY 2023, the Board approved new licenses for 89 collection agencies and an

additional 57 branch locations. As of the end of FY 2023, the Board had licensed 1,103 individual collection agencies

and 468 associated branch offices.

In order to remain connected to multistate activities and informed on nationwide trends, the Board continues to

actively participate in the North American Collection Agency Regulatory Association (NACARA). NACARA is a

trade association of regulator members with the primary purpose of ensuring fair and equitable administration and

enforcement of collection agency regulatory laws. In FY 2023, a staff member was re-appointed as Chair for the

NACARA Annual Conference Planning Committee. Moreover, members of the Board and Office staff attended

NACARA’s 2022 Annual Conference in Nashville. By participating in discussions surrounding multi-state coordination,

the Board plays an active role within the state regulatory community and provides meaningful input into coordinated

debt collection supervision nationwide.

During FY 2023, two vacancies on the Board were filled. Board membership as of June 30, 2023 was:

Chairman: Antonio P. Salazar

Industry Member: Sandra Holland

Industry Member: Shawn Kennedy

Consumer Member: Eric Friedman

Consumer Member: Tracy Rezvan

LICENSING BOARD

Page 46 of 84

Financial Regulation Annual Report 2023

On May 15, 2018, the Financial Consumer

Protection Act of 2018 (2018 Md. Laws 732)

(“2018 Consumer Protection Act”) was signed

into law establishing a Student Loan Ombudsman

to be designated by the Commissioner. The

Ombudsman position was created to provide

student loan borrowers with a state-level office

that can assist them in resolving their complaints

about student loan servicers.

The Ombudsman is also required to monitor

and disseminate information about student loan

servicing activity in Maryland in order to inform

the public and legislature, provide pertinent

analysis and any recommendations to the General

Assembly and to establish, in consultation with

the Commissioner, a student loan borrower

education course by October 1, 2019. Finally, the

Ombudsman is empowered, through subsequent

legislation discussed below, to refer any violations

of student loan servicing standards or instances

of abusive, unfair, deceptive, or fraudulent

practices to the Office’s Enforcement Unit or

to the Maryland Office of the Attorney General

for civil enforcement or criminal prosecution.

The Office began implementation of the 2018

Consumer Protection Act in FY 2019. The

Ombudsman continues to be supported by Office

staff in developing OFR’s capabilities to provide

student loan-related information to the public and

to act as a liaison between Maryland student loan

borrowers and student loan servicers. In this role

as a liaison, the Ombudsman seeks correction

of mistakes and facilitates solutions to student

loan borrowers’ issues.

In 2020, the Ombudsman published a Student

Loan Borrower’s Bill of Rights for Maryland

residents. Based on the 2018 Act and 2019

legislation that enhanced it, the Bill of Rights

provides guidance to Maryland residents who are

repaying student loans. The document succinctly

describes, in plain language, the protections to

which borrowers are entitled as well as clearly

stating the standards that student loan servicers

must meet related to responsiveness, payment

allocation, record retention, and reporting to credit bureaus. The Student

Loan Borrower’s Bill of Rights is intended to serve as a tool for student

loan borrowers to use in their interactions with their loan servicers. The

Student Loan Borrower’s Bill of Rights is available on OFR’s website at

labor.maryland.gov/finance/consumers/frslbillofrights.pdf.

In FY 2023, the Ombudsman provided testimony to the Maryland

Legislature on bills that would impact borrowers. The Ombudsman

also began planning to implement House Bill 913 – Financial Institutions

- Student Financing Companies - Required Registration and Reporting.

The new law requires student financing companies to register with

OFR through NMLS and to report to OFR 15 data points beginning

March 15, 2024. The law goes into effect October 1, 2023. Additionally,

the Ombudsman is preparing to update the website with recent law

and regulatory changes from the Department of Education. Finally, the

Ombudsman began planning the creation of materials that Maryland

State agencies, nonprofits, and others can use to inform their staff

about Public Service Loan Forgiveness.

In FY 2023, the Ombudsman began offering video chat appointments

when helpful to borrowers. Throughout FY 2023, the Ombudsman

continued to assist student loan borrowers with their inquiries and

remained engaged with the U.S. Department of Education and

counterparts in other states on developments regarding student loan

account transfers, return to repayment after the pandemic-related

payment pause for federal loans, and the Public Service Loan Forgiveness

issues. The Ombudsman presented to four different stakeholder

groups about student loans, repayment options, and the role of the

Ombudsman’s Office in Maryland. The stakeholder groups included

legal advocates, financial aid administrators, consumer representatives,

and members of the Financial Education and Capability Commission.

The Ombudsman also participated in the Commissioner’s quarterly

listening sessions with Maryland statewide consumer advocacy leaders

to keep them apprised of student loan industry developments. Complete

details of the activities of the position are available in the Ombudsman’s

Annual Reports, which are submitted to the General Assembly each year.

STUDENT LOAN

Monitoring the Student Loan Servicing Industry and Assisting Student Loan Borrowers

OMBUDSMAN

Page 47 of 84

Financial Regulation Annual Report 2023

OUTREACH AND

Informing Stakeholders and Educating Consumers

The Outreach Unit is responsible for conducting and coordinating

outreach and education to consumers, industry, government,

and nonprofit partners about issue areas within the jurisdiction of

the Office. The Unit’s outreach to stakeholder groups provides

information and training about OFR’s authority and new and existing

laws, while also giving OFR an opportunity to solicit feedback from

those same stakeholders. The Unit’s consumer-focused activities

educate Maryland residents of their rights under State law and

provide information about the role of the Office, including OFR’s

authority to investigate complaints about regulated financial

service providers and activities. In FY 2023, the Unit organized or

participated in 42 events, conferences, and stakeholder meetings

on behalf of OFR.

The Outreach Unit continues to maintain OFR’s website pages and

manage electronic communications. In FY 2023, the Unit created four

new consumer-focused web pages on bank and credit union topics

(account fees, deposit insurance, state and federal regulation, and

where to submit consumer complaints). The Unit also issued 15

industry and consumer advisories and drafted social media posts

and press releases throughout the year.

In the last quarter of FY 2023, the Unit began implementation of

House Bill 379/Senate Bill 929 (Commissioner of Financial Regulation

- Name and Organization of Office), which passed during the 2023

Maryland General Assembly session and became effective at the start

of FY 2024, on July 1, 2023. The new law changes the name of the

Office to the “Office of Financial Regulation’’ (from the “Office of the

Commissioner of Financial Regulation”). The Office’s name change

required revisions to the Office’s official seal, and subsequently all

outreach and communication materials needed to be reviewed,

updated and rebranded, including webpages, factsheets and

brochures, presentation and advisory templates, and event

materials/giveaways.

The Unit also hired an additional staff person in FY 2023. The

“Outreach and Education Associate” is a new position created to

provide support and in-house technical expertise to the Director

of Outreach and Education, primarily in the areas of graphic design

and electronic communications.

Stakeholder Outreach

Throughout FY2023 the Outreach Unit remained engaged with a

variety of industry and government partners, and was in frequent

communication with leadership and staff of nonprofit consumer

advocacy groups, financial education practitioners, and community

organizations. The Unit provided updates to these stakeholders

about the activities of the Office and shared

information about the financial service industries

and activities regulated by OFR and consumer

complaint investigations.

The Unit’s stakeholder outreach in FY 2023

included:

• Organizing and hosting an informational

Q&A session for mortgage servicers about

Maryland HAF. This webinar was presented

in partnership with Maryland DHCD as

a follow-up session to the HAF webinar

hosted by OFR in FY 2022.

• Conducting OFR’s third annual “Regulatory

Highlights” webinar, a live-streamed event

for regulated industries and interested

consumer groups, during which OFR

staff and leadership provided legislative,

supervisory, and enforcement updates.

The webinar was attended by 274

individuals and the recording has

been viewed 52 times.

• Conducting two webinars on climate

change risks for Maryland-chartered

banks and credit unions. The webinars

provided guidance from the Commissioner

with respect to the financial institutions’

handling of the various risks posed by

climate change and on the establishment

of governance structures to manage

those risks.

• Conducting seven webinars for nonprofit

housing counselors, financial educators,

and legal service agencies about OFR’s

authority in the foreclosure process,

consumer complaint investigations, and

consumer financial protections enforced

by OFR. The Unit also provided updates

on foreclosure data and OFR’s regulatory

activities during meetings for the COVID-19

Housing Preservation Coalition and the

Community Development Network of

Maryland.

EDUCATION

Page 48 of 84

Financial Regulation Annual Report 2023

• Hosting four virtual “Listening Sessions with the Commissioner”

with statewide consumer advocacy leaders.

• Presenting about the Foreclosure Registration System during a

staff meeting for the Baltimore City Planning Department. The

Foreclosure Registration System is an online reporting database

for lenders and foreclosure purchasers overseen by OFR - the

data available in the Foreclosure Registration System is accessible

to local governments to assist with nuisance abatement and

other issues that may arise from foreclosed properties in their

jurisdictions.

• Participating in the Maryland Association of Counties

Conference’s two-day exhibitor hall to share information with

Maryland’s local officials about the services provided by OFR,

with an emphasis on the Foreclosure Registration System.

Outreach staff and OFR leadership continued to participate in

meetings of the General Assembly’s Financial Education and

Capability Commission, the Maryland Project SAFE (“Stop Adult

Financial Exploitation”) partnership, and numerous regional meetings

with nonprofit housing counseling, legal service, and community

development agencies.

Consumer Education

The Outreach Unit’s consumer-focused activities involve direct-to-

consumer education in the form of written or electronic materials,

including videos, presentations, advisories and factsheets, or through

engagement at public events. The Unit partners with local nonprofits

and other state or federal agencies as a participant in their financial

education events or public campaigns. The Outreach Unit also

provides support to the Student Loan Ombudsman by assisting with

outreach to Maryland student loan borrowers about their rights and

responsibilities and providing information to

borrowers and stakeholders on how to access

additional state and federal resources.

In FY 2023, Outreach Unit staff participated

in six in-person outreach events organized by

nonprofit or government agencies, and served

as a panelist on a live-streamed foreclosure

prevention webinar for homeowners organized

by the Montgomery County Office of Consumer

Protection. The Unit also manages OFR’s direct

outreach to homeowners at risk of foreclosure

by mailing informational letters and resource

factsheets to those who have received

foreclosure warning notices (“Notices of

Intent to Foreclose’’) from their lenders. Over

79,462 foreclosure outreach letters were

mailed in FY 2023.

The Outreach Unit coordinated the Office’s

participation in 2023 Protect Week, an annual

statewide public education campaign that arose

out of a collaboration between federal, state,

and local nonprofits and government agencies

to highlight the growing problem of financial

abuse of older Marylanders. During 2023

Protect Week, Commissioner Salazar spoke at

a press conference with other agency leaders,

including representatives from the Maryland

Office of the Attorney General, Maryland

Comptroller’s Office, Maryland Department

of Aging, Maryland Department of Human

Services, AARP of Maryland, and the U.S.

Department of Justice. Commissioner Salazar

also participated in a live-streamed interview

with AARP where he discussed smartphone

apps and peer-to-peer payment services,

describing the Office’s role in regulating these

emerging technologies and in protecting

Maryland’s older consumers from financial

exploitation generally. Outreach Unit staff

participated in two public resource fairs for

older adults during Protect Week.

OFR Outreach staff with hometown baseball team mascot,

the Baltimore Oriole.

Financial Regulation Annual Report 2023 Page 49 of 84

Facts and figures for

state-chartered and

depository financial

institutions, financial

statements for the

Office, and historical

lists of Commissioners.

APPENDICES

Page 50 of 84

Financial Regulation Annual Report 2023

Fig 1 Consolidated Statement of Financial Condition – State-Chartered Banks Page 51

Fig 2 Ratios from Consolidated Statements of Financial Condition of All State-Chartered Banks Page 52

Fig 3 Bank Prior Period End Totals Page 53

Fig 4 State-Chartered Bank Growth Trends Page 53

Fig 5 State-Chartered Commercial Banks & Savings Banks – Principal Location, Assets, & CRA Ratings Page 54

Fig 6 Other Banks Operating in Maryland – Principal Location, Deposits, & Branches Page 55

Fig 7 National Banks & Federal Savings Banks Headquartered in Maryland – Principal Location & Total Assets Page 57

Fig 8 FDIC Insured Banks - Trend Year-Over-Yearr Page 57

Fig 9 Consolidated Statement of Financial Condition – State-Chartered Credit Unions Page 58

Fig 10 Ratios from Consolidated Statements of Financial Condition-All State-Chartered Credit Unions Page 58

Fig 11 Credit Union Prior Period End Totals Page 59

Fig 12 State-Chartered Credit Union Growth Trends Page 59

Fig 13 State-Chartered Credit Unions – Assets and Field of Membership Typese Page 60

Fig 14 Selected Balance Sheet Items – State-Chartered Credit Unions Page 60

Fig 15 NCUA Insured Credit Unions - Trend Year-Over-Year Page 61

Fig 16 Federal Credit Unions – Operating Branches in Maryland Page 61

Fig 17 Federal Credit Unions – Headquartered in Maryland Page 62

Fig 18 State-Chartered Non-Depository Trust Companies – Location and Business Type Page 64

Fig 19 Trust Assets Reported by State-Chartered Trust Companies Page 64

Fig 20 State-Chartered Trust Companies Asset Growth Trends Page 65

Fig 21 Maryland Trust Companies Asset Growth Trends Page 65

Fig 22 Banks, Credit Unions, and Trust Companies Page 66

State-Chartered and Depository Institutions – Facts & Figures

APPENDIX A:

Page 51 of 84

Financial Regulation Annual Report 2023

FIGURE 1. Consolidated Statement of Financial Condition – State-Chartered Banks

Fiscal Years Ended June 30th (in thousands)

ASSETS FY 2023 FY 2022 FY 2021

% Change

FY22-FY23

Non-Interest Bearing & Currency/Coin $316,683 $423,732 $452,072 -25.26%

Interest Bearing Balances $2,753,030 $3,414,331 $4,153,113 -19.37%

Securities $7,903,790 $7,500,538 $5,867,990 5.38%

Federal Funds Sold and Securities Purchased Under

Agreements to Sell

$32,644 $121,033 $445,109 -73.03%

Loans and Leases, Net of Unearned Income $36,161,514 $33,411,669 $32,272,396 8.23%

(Allowance for Loan and Lease Losses) -$450,773 -$362,170 -$391,771 24.46%

Trading Account Assets $30,702 $18,630 $5,548 64.80%

Premises and Fixed Assets (including capitalized leases) $397,001 $377,000 $443,404 5.31%

Other Real Estate Owned $10,914 $16,916 $36,703 -35.48%

Intangible Assets $630,389 $630,586 $686,711 -0.03%

Other Assets $1,439,968 $1,227,784 $1,204,965 17. 28%

Total Assets $49,676,635 $47,142,219 $45,568,011 5.38%

LIABILITIES FY 2023 FY 2022 FY 2021

% Change

FY22-FY23

Total Deposits $40,296,292 $40,559,095 $38,303,678 -0.65%

Federal Funds Purchased & Repurchase Agreements $271,271 $320,198 $274,748 -15.28%

Trading Liabilities $32,341 $17,673 $5,721 83.00%

Subordinated Debt $ - $ - $30,543 -%

Other Borrowed Funds $3,162,434 $768,473 $1,105,018 311.52%

Other Liabilities $524,716 $387,413 $364,808 35.44%

Total Liabilities $44,287,054 $42,052,852 $40,084,516 5.31%

EQUITY CAPITAL FY 2023 FY 2022 FY 2021

% Change

FY22-FY23

Perpetual Preferred Stock $ - $ - $ -

Common Stock $121,681 $123,563 $138,521 -1.52%

Surplus $3,167,020 $3,054,733 $3,043,551 3.68%

Undivided Profits and Capital Reserves $2,100,880 $1,911,071 $2,301,423 9.93%

Total Equity Capital $5,389,581 $5,089,367 $5,483,495 5.90%

Total Liabilities and Equity $49,676,635 $47,142,219 $45,568,011 5.38%

SOURCE: OFR compiled using FDIC data tools

Page 52 of 84

Financial Regulation Annual Report 2023

FIGURE 2. Ratios from Consolidated Statements of Financial Condition of All State-Chartered Banks

Fiscal Years Ended June 30th

Year Ended June 30th FY 2023 FY 2022 FY 2021 FY 2020

Return on Assets 1.35% 1.49% 1.67% 0.50%

Net Interest Margin 3.66% 3.53% 3.49% 3.61%

Total Loans to Total Deposits 89.74% 82.38% 84.25% 96.39%

Total Loans to Core Deposits 115.87% 92.58% 96.31% 110.92%

Total Loans to Total Assets 72.79% 70.87% 70.82% 77.47%

ALLL* to Total Loans 1.23% 1.07% 1.20% 1.28%

Noncurrent Loans to Total Loans 0.77% 0.47% 0.88% 0.84%

Tier 1 Leverage Capital 13.38% 10.61% 10.99% 10.57%

Tier 1 Risk-Based Capital ** ** ** **

Total Risk-Based Capital 14.31% 14.19% 15.92% 14.13%

Common Equity Tier 1 Capital ** ** ** **

* = Allowance for Loan and Lease Losses

** As of March 2020, not available for institutions that have elected the Community Bank Leverage Ratio (CBLR) framework

and not available for most standard peer groups.

SOURCE: OFR calculated

Page 53 of 84

Financial Regulation Annual Report 2023

FIGURE 4. State-Chartered Bank Growth Trends

FIGURE 3. Bank Prior Period End Totals

Fiscal Years Ended June 30th (in thousands)

YEAR TOTAL ASSETS TOTAL LOANS SECURITIES TOTAL DEPOSITS TOTAL CAPITAL

2023 $49,676,635 $36,161,414 $7,903,790 $40,296,292 $5,389,581

2022 $47,142 ,219 $33,411,669 $7,500,538 $40,559,095 $5,089,367

2021 $45,568,011 $32,272,467 $5,867,990 $38,303,678 $5,483,495

2020 $41,836,704 $32,387,626 $3,747,885 $33,705,264 $4,862,555

2019 $41,398,131 $32,918,168 $4,027,665 $33,083,982 $5,437,638

2018 $39,409,185 $31,067,419 $3,922,176 $30,921,037 $4,910,628

2017 $34,018,542 $26,405,546 $3,820,310 $27,478,399 $3,889,011

2016 $30,855,474 $23,696,672 $3,825,527 $25,124,361 $3,369,988

SOURCE: OFR compiled using FDIC data tools

Page 54 of 84

Financial Regulation Annual Report 2023

FIGURE 5. State-Chartered Commercial Banks and Savings Banks – Principal Location, Assets, and CRA Ratings

Fiscal Year Ended June 30, 2023

BANK NAME

PRINCIPAL

LOCATION

TOTAL

ASSETS (in

thousands)

TOTAL

DEPOSITS (in

thousands)

TOTAL

BRANCHES

NO. OF LMI

BRANCHES

(as % of

total)*

CRA

RATING

The Bank of Glen Burnie Glen Burnie $363,583 $329,315 8 0 (0%) Satisfactory

Bank of Ocean City Ocean City $629,468 $570,544 6 0 (0%) Satisfactory

BayVanguard Bank Baltimore $912,123 $730,497 15 2 (13%) Outstanding

Calvin B. Taylor Banking Company of

Berlin, Maryland

Berlin $884,795 $784,435 13 3 (23%) Satisfactory

Cecil Bank Elkton $226,591 $196,974 4 1 (25%) Satisfactory

CFG Bank Baltimore $5,075,789 $4,523,257 3 0 (0%) Satisfactory

The Chesapeake Bank and Trust Co. Chestertown $122,685 $99,820 3 0 (0%) Satisfactory

Community Bank of the Chesapeake Waldorf $2,460,952 $2,138,028 12 2 (17%) Satisfactory

EagleBank Bethesda $10,982,157 $7,754,101 15 2 (13%) Satisfactory

Farmers and Merchants Bank Upperco $730,236 $633,576 8 0 (0%) Satisfactory

The Farmers Bank of Willards Willards $550,015 $453,030 8 0 (0%) Satisfactory

First United Bank & Trust Oakland $1,906,497 $1,594,658 26 5 (19%) Satisfactory

Forbright Bank Potomac $6,612,085 $5,694,472 5 1 (20%) Satisfactory

Glen Burnie Mutual Savings Bank Glen Burnie $108,477 $99,061 1 0 (0%) Satisfactory

The Harbor Bank of Maryland Baltimore $372,757 $332,404 7 5 (71%) Satisfactory

Harford Bank Aberdeen $626,262 $538,253 10 2 (20%) Satisfactory

Hebron Savings Bank Hebron $750,974 $662,212 13 4 (31%) Satisfactory

Middletown Valley Bank Middletown $974,307 $854,584 8 1 (13%) Satisfactory

The Peoples Bank Chestertown $319,859 $289,314 7 1 (14%) Satisfactory

The Queenstown Bank of Maryland Queenstown $676,818 $594,144 9 0 (0%) Satisfactory

Sandy Spring Bank Olney $13,987,426 $11,041,547 56 8 (14%) Satisfactory

Woodsboro Bank Woodsboro $402,779 $382,066 5 3 (14%) Satisfactory

TOTAL MD CHARTERED BANKS: 22 $49,676,635 $40,296,292 242 40 (17%)

TOTAL OTHER BANKS OPERATING IN MD: 55** $159,436,149 1,016

* Branch LMI designations may vary year-to-year due to annual changes in census tract income levels.

** See Figure 6 for detailed list of other banks operating in Maryland.

SOURCE: FFIEC and State-Chartered Bank websites

Page 55 of 84

Financial Regulation Annual Report 2023

FIGURE 6. Other Banks Operating in Maryland – Principal Location, Deposits, and Branches

Fiscal Year Ended June 30, 2023

BANK NAME

STATE

(Headquartered)

TOTAL DEPOSITS

in MD

(in thousands)

TOTAL

BRANCHES

in MD

ACNB Bank PA $620,338 9

Ameriserv Financial Bank PA $17,218 1

Arundel Federal Savings Bank MD $352,834 6

Atlantic Union Bank VA $75,258 1

Bank of America, National Association NC $43,478,940 127

Bank of Charles Town WV $33,444 1

Capital Bank, National Association MD $1,498,363 2

Capital One, National Association VA $13,663,044 43

Cathay Bank CA $122,988 1

CIBC National Trust Company GA $ - 1

Citibank, National Association SD $2,600,000 10

Citizens Bank, National Association RI $117,595 4

Clear Mountain Bank WV $73,259 1

CNB Bank, Inc. WV $139,552 3

Dollar Bank, FSB PA $75,600 2

Eastern Savings Bank, FSB MD $236,045 5

Farmers and Merchants Trust Company of Chambersburg PA $6,153 1

First National Bank of Pennsylvania PA $3,437,676 31

First Shore Federal Savings and Loan Association MD $254,901 5

First-Citizens Bank & Trust Company NC $131,870 2

Firstrust Savings Bank PA $33,522 1

Fulton Bank, National Association PA $2,187,794 25

FVCbank VA $91,677 3

Homewood Federal Savings Bank MD $45,206 1

Industrial Bank DC $107,001 2

Jarrettsville Federal Savings and Loan Association MD $129,004 1

Jefferson Security Bank WV $6,442 1

John Marshall Bank VA $92,558 1

JP Morgan Chase Bank, National Association OH $1,644,816 32

Continued on next page.

Page 56 of 84

Financial Regulation Annual Report 2023

BANK NAME

STATE

(Headquartered)

TOTAL DEPOSITS

in MD (in

thousands)

TOTAL

BRANCHES

in MD

Manufacturers and Traders Trust Company NY $23,017, 296 167

Miners & Merchants Bank WV $6,876 1

Orrstown Bank PA $469,813 5

Peoples Bank OH $21,946 1

Peoplesbank, A Codorus Valley Company PA $299,507 4

PNC Bank, National Association DE $18,060,853 146

Presidential Bank, FSB MD $501,745 4

Primis Bank VA $191,666 2

Rosedale Federal Savings and Loan Association MD $951,214 14

Shore United Bank, N.A. MD $2,673,454 24

Somerset Trust Company PA $56,110 3

Stifel Trust Company, National Association MO $ - 1

Summit Community Bank, Inc. WV $472,533 9

TD Bank, National Association DE $2,427,192 19

The Bank of Delmarva DE $442,889 9

The National Capital Bank of Washington DC $26,165 1

Truist Bank NC $22,436,868 145

Trustar Bank VA $13,212 1

United Bank VA $1,407,430 11

Univest Bank and Trust Co. PA $1,645 1

Virginia Partners Bank VA $78,908 1

Wells Fargo Bank, National Association SD $12,352,801 81

Wesbanco Bank, Inc. WV $2,146,289 29

Wilmington Trust, National Association DE $ - 1

Woodforest National Bank TX $34,247 12

Woori America Bank NY $72,392 1

Number of Institutions in the Market: 55 $159,436,149 1,016

SOURCE: FDIC Deposit Market Share Reports - Summary of Deposits

FIGURE 6. Other Banks Operating in Maryland – Principal Location, Deposits, and Branches (cont.)

Fiscal Year Ended June 30, 2023

Page 57 of 84

Financial Regulation Annual Report 2023

FIGURE 7. National Banks & Federal Savings Banks Headquartered in Maryland – Principal Location & Total Assets

Fiscal Year Ended June 30, 2023 (in thousands)

BANK PRINCIPAL LOCATION

TYPE OF

CHARTER

TOTAL ASSETS

Arundel Federal Savings Bank Glen Burnie, MD FSB $445,683

Capital Bank, N.A. Rockville, MD NB $2,174,128

Eastern Savings Bank, FSB Hunt Valley, MD FSB $355,791

First Shore Federal Savings & Loan Assoc. Salisbury, MD FSB $330,033

Homewood Federal Savings Bank Baltimore, MD FSB $61 ,746

Jarrettsville Federal Savings & Loan Assoc. Jarrettsville, MD FSB $146,715

Presidential Bank, FSB Bethesda, MD FSB $846,094

Rosedale Federal Savings & Loan Assoc. Nottingham, MD FSB $1,237,848

Shore United Bank, N.A. Easton, MD NB $3,639,919

TOTAL: 9 $9,237,957

FIGURE 8. FDIC Insured Banks - Trend Year-Over-Year

Fiscal Years Ending June 30th ($ in thousands)

Year

Number

of MD

Chartered

Banks

Total

Assets MD

Chartered

Banks*

Number

of FDIC

Insured

Banks**

Total Assets All

FDIC Insured

Banks

% of MD

Chartered Banks

to All FDIC

Insured Banks

% of MD Chartered

Bank Assets to All

FDIC Insured Bank

Assets

2023 22 $49,676,635 4,645 $23,465,090,000 0.474% 0.212%

2022 23 $47,142, 219 4,771 $23,718,485,898 0.482% 0.199%

2021 26 $45,568,011 4,951 $22,789,003,236 0.525% 0.200%

2020 28 $41,836,704 5,066 $21,139,330,398 0.553% 0.198%

2019 32 $41,398,131 5,303 $18,265,870,678 0.603% 0.227%

2018 35 $39,409,185 5,542 $17,532,878,340 0.632% 0.225%

2017 40 $34,018,542 5,738 $17,242,501,094 0.697% 0.197%

2016 41 $30,855,474 6,058 $16,533,969,432 0.677% 0.187%

2015 46 $28,478,385 6,348 $15,753,630,867 0.725% 0.181%

* MD chartered banks are FDIC insured

** All U.S. FDIC insured banks

SOURCE: National Bank and Federal Savings Bank Call Reports

SOURCE: FDIC State Banking Performance Summary

Page 58 of 84

Financial Regulation Annual Report 2023

FIGURE 9. Consolidated Statement of Financial Condition – State-Chartered Credit Unions

Comparative Figures for Fiscal Years Ended June 30th (in thousands)

ASSETS FY 2023 FY 2022 FY 2021

% Change FY22-

FY23

Cash & Balances Due From Depository Inst. $417,797 $320,668 $1,023,274 30.29%

Investments & Securities $1,401,021 $1,668,955 $1,830,736 -16.05%

Total Loans $5,558,440 $5,309,748 $4,094,893 4.68%

Allowance for Loan and Lease Losses -$52,804 -$37,419 -$50,504 41.12%

Premises and Fixed Assets $123,430 $122,369 $79,073 0.87%

Other Assets $386,008 $322,016 $270,066 19.87%

Total Assets $7,952 ,061 $7,812 ,560 $6,682,139 1.79%

LIABILITIES FY 2023 FY 2022 FY 2021

% Change FY22-

FY23

Members’ Shares and Deposits $6,694,963 $6,779,447 $6,517,717 -1.25%

Borrowed Money $439,286 $287, 214 $52,143 52.95%

Other Liabilities $161,027 $117,109 $67,641 37.50%

Total Liabilities $7,295,276 $7,183,770 $6,637,502 1.55%

Total Net Worth $811,808 $757,461 $718,118 7.17%

Total Liabilities and Equity $7,952,061 $7,812,560 $7,342,133 1.79%

FIGURE 10. Ratios from Consolidated Statements of Financial Condition – All State-Chartered Credit Unions

Fiscal Years Ended June 30th

Additional Information as of June 30th 2023 2022 2021 2020

Net Worth to Total Assets 10.21% 9.70% 9.78% 10.27%

Net Worth to Members’ Shares & Deposits 12.13% 11.17% 11.02% 11.67%

Total Loans to Total Assets 69.90% 67.96% 55.77% 69.97%

Total Loans to Members’ Shares & Deposits 83.02% 78.32% 62.83% 79.50%

ALLL* to Total Loans 0.95% 0.70% 1.23% 0.87%

Return on Assets (annualized) 0.75% 0.33% 0.48% 0.18%

* = Allowance for Loan and Lease Losses

SOURCE: State-Chartered Credit Union Call Reports

SOURCE: OFR

Page 59 of 84

Financial Regulation Annual Report 2023

FIGURE 12. State-Chartered Credit Union Growth Trends

FIGURE 11. Credit Union Prior Period End Totals

Fiscal Years Ended June 30th (in thousands)

YEAR TOTAL ASSETS TOTAL LOANS SHARES & DEPOSITS TOTAL CAPITAL

2023 $7,952,061 $5,558,440 $6,694,963 $811,808

2022 $7,812,560 $5,309,748 $6,779,447 $757,461

2021 $7,342,133 $4,094,893 $6,517,717 $718,118

2020 $6,682,139 $4,675,647 $5,881,260 $686,290

2019 $6,089,506 $4,655,584 $5,327,541 $649,009

2018 $5,897,917 $4,491,816 $5,148,133 $624,210

2017 $5,637,718 $4,172,460 $4,947,779 $606,295

2016 $5,343,323 $3,749,515 $4,692,960 $586,882

SOURCE: State-Chartered Credit Union Call Reports

Page 60 of 84

Financial Regulation Annual Report 2023

FIGURE 13. State-Chartered Credit Unions – Assets and Field of Membership Types

Fiscal Year Ended June 30, 2023

NAME

PRINCIPAL

LOCATION

TOTAL

ASSETS

(in thousands)

TOTAL

DEPOSITS

(in thousands)

LOW-

INCOME

DESIGNATION

NO. OF

BRANCHES

NO. OF LMI

BRANCHES

(as % of

total)*

FIELD OF

MEMBERSHIP

TYPE

Central Credit Union

of Maryland

Towson $46,473 $41,949 Yes 2 0 (0%)

Multiple

Common Bond

Destinations Credit

Union

Parkville $65,950 $58,976 Yes 2 0 (0%)

Multiple

Common Bond

HAR-CO Credit

Union

Bel Air $250,155 $226,070 No 3 1 (33%)

Community

Common Bond

Municipal Employees

Credit Union of

Baltimore (MECU)

Baltimore $1,300,908 $1,122,904 Yes 9 7 (78%)

Multiple

Common Bond

Point Breeze Credit

Union

Hunt Valley $929,078 $803,153 No 5 1 (20%)

Multiple

Common Bond

Post Office Credit

Union of MD, Inc.

Baltimore $31,252 $23,651 ** 1 1 (100%)

Single

Common Bond

State Employees

Credit Union of

Maryland, Inc. (SECU)

Linthicum $5,328,245 $4,418,260 Yes 25 4 (16%)

Multiple

Common Bond

TOTAL: 7 $7,952,061 $6,694,963 47 14 (30%)

* Branch LMI designations may vary year-to-year due to annual changes in census tract income levels

** Post Office Credit Union of MD, Inc. is privately insured by ASI. The NCUA low-income designation does not apply.

FIGURE 14. Selected Balance Sheet Items – State-Chartered Credit Unions

Fiscal Year Ended June 30, 2023 (in thousands)

CREDIT UNION NAME TOTAL ASSETS

TOTAL

LOANS

SHARES &

DEPOSITS

TOTAL

CAPITAL

ASI Private Share Insurance

Post Office Credit Union of MD, Inc. $31,252 $7, 201 $23,651 $7,488

National Credit Union Share Insurance

Central Credit Union of MD, Inc. $46,473 $19,173 $41,949 $4,549

Destinations Credit Union $65,950 $31,153 $58,976 $8,744

HAR-CO Credit Union $250,155 $168,991 $226,070 $21,394

Municipal Employees Credit Union of Baltimore, Inc. $1,300,908 $799,227 $1,122,904 $153,787

Point Breeze Credit Union $929,078 $574,101 $803,153 $124,565

State Employees Credit Union of MD, Inc. $5,328,245 $3,958,594 $4,418,260 $491,281

Total All Maryland State-Chartered Credit Unions $7,952,061 $5,558,440 $6,694,963 $811,808

SOURCE: State-Chartered Credit Union Call Reports

SOURCES: NCUA, FFIEC and State-Chartered Bank websites

Page 61 of 84

Financial Regulation Annual Report 2023

FIGURE 15. NCUA Insured Credit Unions - Trend Year-Over-Year

Fiscal Years Ended June 30th ($ in thousands)

Year

Number of

NCUA Insured

MD Chartered

Credit Unions

Total Assets of

NCUA Insured

MD Chartered

Credit Unions*

Number

of NCUA

Insured Credit

Unions**

Total Assets All

NCUA Insured

Credit Unions

% of MD

Chartered Credit

Unions to All

NCUA Insured

Credit Unions

% of MD Chartered

Credit Union Assets

to All NCUA Insured

Credit Union Assets

2023 6 $7,920, 809 4,686 $2,220,000,000 0.130% 0.357%

2022 6 $7,778, 355 4,853 $2,140,000,000 0.120% 0.363%

2021 6 $7,308,307 5,029 $1,980,000,000 0.120% 0.369%

2020 6 $6,649,694 5,164 $1,750,000,000 0.120% 0.380%

2019 6 $6,058,053 5,308 $1,520,000,000 0.110% 0.399%

SOURCE: NCUA

FIGURE 16. Federal Credit Unions – Operating Branches in Maryland

Fiscal Year Ended June 30, 2023

NAME PRINCIPAL LOCATION

LOW-INCOME

DESIGNATION

OFFICES

Agriculture Federal Credit Union (AgFed) Washington, DC Yes 2

Baxter Credit Union (BCU), FCU Vernon Hills, IL No 1

Democracy Federal Credit Union Alexandria, VA Yes 1

Department of Commerce Federal Credit Union Washington, DC Yes 1

InFirst Federal Credit Union Alexandria, VA Yes 1

John Wesley AME Zion Church Federal Credit Union Washington, DC Yes 1

Navy Federal Credit Union Vienna, VA No 22

Northrop Grumman Federal Credit Union Gardena, CA No 3

Northwest Federal Credit Union Herndon, VA Yes 1

Partners 1st Federal Credit Union Fort Wayne, IN Yes 2

Patriot Federal Credit Union Chambersburg, PA Yes 3

Pentagon Federal Credit Union McLean, VA No 1

Spectra Federal Credit Union Alexandria, VA Yes 1

Treasury Department Federal Credit Union Washington, DC Yes 1

TOTAL: 14 41

SOURCE: NCUA

* MD chartered Post Office Credit Union of Maryland is privately insured

** All U.S. NCUA insured credit unions

Page 62 of 84

Financial Regulation Annual Report 2023

FIGURE 17. Federal Credit Unions – Headquartered in Maryland

Fiscal Year Ended June 30, 2023

NAME

PRINCIPAL

LOCATION

TOTAL ASSETS

(in thousands)

TOTAL DEPOSITS

(in thousands)

LOW-INCOME

DESIGNATION

OFFICES

in MD

Aberdeen Proving Ground (APG) FCU Edgewood $2,160,702 $1,945,586 No 13

ACT 1st Federal Credit Union Lavale $144,739 $133,064 Yes 3

Andrews Federal Credit Union Suitland $2,424,418 $1,920,981 Yes 3

APL Federal Credit Union Laurel $631,686 $556,755 No 3

Atlantic Financial Federal Credit Union Hunt Valley $105,342 $96,006 No 2

Baltimore County Employees FCU Towson $498,107 $472,538 No 3

Baltimore Washington Federal Credit Union Glen Burnie $10,229 $9,424 Yes 1

BEE Federal Credit Union Salisbury $8,180 $6,487 Yes 1

Bulldog Federal Credit Union Hagerstown $225,242 $219,068 Yes 8

Capital Area Realtors Federal Credit Union Rockville $21,297 $19,006 Yes 1

Capital Area Taiwanese Federal Credit Union Boyds $13,820 $11,712 No 1

Cecil County School Employees FCU Elkton $28,432 $25,733 No 1

Cedar Point Federal Credit Union Lexington Park $749,728 $691,035 No 6

Census Federal Credit Union Suitland $52,278 $45,812 No 1

Chessie Federal Credit Union Cumberland $435,408 $390,125 Yes 8

Choptank Electric Co-Op Employees FCU Denton $2,915 $2,156 No 1

Delmarva Power Southern Division FCU Salisbury $18,254 $14,605 Yes 1

Educational Systems Federal Credit Union Greenbelt $1,306,486 $1,122,344 No 14

FedChoice Federal Credit Union Lanham $431,167 $395,252 Yes 2

FedFinancial Federal Credit Union Silver Spring $85,103 $78,207 No 2

FERKO Maryland Federal Credit Union Frederick $35,816 $31,419 No 1

First Eagle Federal Credit Union Owings Mills $110,920 $99,365 Yes 2

First Financial Of Maryland FCU Sparks $1,266,890 $997,005 No 8

First Peoples Community FCU Cumberland $569,778 $499,934 Yes 11

Five Star Federal Credit Union Baltimore $59,445 $52,217 Yes 3

Freedom Federal Credit Union Bel Air $437,550 $387,889 No 6

Greenbelt Federal Credit Union Greenbelt $37,607 $33,760 Yes 1

HEMA Federal Credit Union Silver Spring $18,502 $16,820 Yes 1

Howard County Education FCU Ellicott City $25,760 $23,332 No 1

IBEW 26 Federal Credit Union Lanham $31,177 $28,891 No 1

Johns Hopkins Federal Credit Union Baltimore $621,793 $521,106 Yes 4

Korean Catholic Federal Credit Union Olney $2,237 $1,989 No 1

Continued on next page.

Page 63 of 84

Financial Regulation Annual Report 2023

FIGURE 17. Federal Credit Unions – Headquartered in Maryland

Fiscal Year Ended June 30, 2023

NAME

PRINCIPAL

LOCATION

TOTAL ASSETS

(in thousands)

TOTAL DEPOSITS

(in thousands)

LOW-INCOME

DESIGNATION

OFFICES

in MD

Lafayette Federal Credit Union Rockville $1,880,258 $1,564,475 Yes 4

LM Federal Credit Union Baltimore $55,729 $50,757 No 1

Local 355 MD Federal Credit Union Baltimore $6,105 $4,974 No 2

Market USA Federal Credit Union Laurel $140,182 $111,605 Yes 3

Masters, Mates & Pilots (MM&P) FCU Linthicum $3,224 $2,964 No 1

Members First of Maryland FCU Baltimore $26,085 $24,195 Yes 2

Mid-Atlantic Federal Credit Union Germantown $409,746 $370,902 Yes 4

Maryland-National Capital Park and Planning

Commission (MNCPPC) Federal Credit Union

College Park $15,131 $13,105 No 2

Money One Federal Credit Union Largo $119,805 $93,219 Yes 1

Mount Jezreel Federal Credit Union Silver Spring $297 $268 Yes 1

MVP Postal And Printing FCU Gaithersburg $4,078 $3,684 Yes 1

NASA Federal Credit Union Upper Marlboro $5,133,032 $4,088,843 No 7

National Institutes of Health (NIH) FCU Rockville $822,498 $760,792 No 5

None Suffer Lack Federal Credit Union Suitland $24,989 $20,183 Yes 1

Nymeo Federal Credit Union Frederick $356,071 $316,891 Yes 4

Peninsula General Hospital & Medical

Center Employees Federal Credit Union

Salisbury $45,343 $3,464 No 1

Police Federal Credit Union Upper Marlboro $173,593 $150,391 No 1

Prince George’s Community FCU Bowie $253,387 $220,051 Yes 3

Securityplus Federal Credit Union Baltimore $557,210 $487,897 Yes 7

Self Reliance Baltimore Federal Credit Union Baltimore $15,911 $14,035 No 1

Signal Financial Federal Credit Union Kensington $420,879 $373,513 Yes 3

SkyPoint Federal Credit Union Germantown $211,496 $176,616 Yes 3

St. Joseph Medical Center FCU Towson $15,700 $13,214 No 1

Thiokol-Elkton Federal Credit Union Elkton $25,001 $21,956 No 1

Tower Federal Credit Union Laurel $4,492,750 $3,750,815 No 17

Transit Employees Federal Credit Union Greenbelt $98,579 $83,603 Yes 1

U.S. Postal Service Federal Credit Union Clinton $264,721 $233,232 Yes 1

WSSC Federal Credit Union Laurel $34,647 $31,920 Yes 2

Washington County Teachers FCU Hagerstown $85,141 $73,461 No 3

WEPCO Federal Credit Union Bloomington $348,395 $297,750 Yes 6

TOTAL: 62 $28,610,991 $24,208,398 205

SOURCE: NCUA

FIGURE 17. Federal Credit Unions – Headquartered in Maryland (c ont.)

Fiscal Year Ended June 30, 2023

Page 64 of 84

Financial Regulation Annual Report 2023

FIGURE 18. State-Chartered Non-Depository Trust Companies – Location and Business Type

Fiscal Year Ending June 30, 2023

FIGURE 19. Trust Assets Reported by State-Chartered Trust Companies

Fiscal Year Ended June 30, 2023 (in thousands)

Full Service Trust Companies Managed Non-Managed Custodial Total

First United Bank & Trust $1,022,002 $60,076 $5,309 $1,087,387

Sandy Spring Bank $1,734,555 $155,644 $35,954 $1,926,153

Total Assets - Full Service Trust Companies $2,756,557 $215,720 $41,263 $3,013,540

Non-Depository Trust Companies Managed Non-Managed Custodial Total

Brown Investment Advisory & Trust Co. $7,371,597 $952,855 - $8,324,452

Chevy Chase Trust Company $13,765,090 $22,237,075 $3,864,056 $39,866,221

NewTower Trust Company $11,883,188 $0 $0 $11,883,188

T. Rowe Price Trust Company $294,562,629 $241,590,786 - $536,153,415

Total Assets - Non-Depository Trust Companies $327,582,504 $264,780,716 $3,864,056 $596,227,276

GRAND TOTAL:

Full Service and Non-Depository Trust

Companies

$330,339,061 $264,996,436 $3,905,319 $599,240,816

TRUST COMPANY NAME PRINCIPAL LOCATION TRUST/FIDUCIARY BUSINESS PURPOSE

Brown Investment Advisory and Trust Co. Baltimore Investment Advisory Services

Chevy Chase Trust Bethesda Investment Management/Financial Planning

NewTower Trust Company Bethesda Trustee for Multi-Employer Property Trust

T. Rowe Price Trust Company Baltimore Investment Management

TOTAL: 4

SOURCE: Trust Company Prepared Call Reports

SOURCE: OFR

Page 65 of 84

Financial Regulation Annual Report 2023

FIGURE 21. Maryland Trust Companies Asset Growth Trends

FIGURE 20. State-Chartered Trust Companies Asset Growth Trends

Fiscal Years Ended June 30th (in thousands)

YEAR Managed Assets Non-managed Assets Custodial Assets Total Assets

2023 $330,339,061 $264,996,436 $3,905,319 $599,240,816

2022 $286,927,341 $246,401,053 $3,400,567 $536,728,961

2021 $310,400,970 $305,973,519 $3,647,858 $620,022,347

2020 $222,254,936 $238,704,184 $3,072,175 $464,031,295

2019 $185,084,556 $242,752,297 $2,888,167 $430,725,020

2018 $154,979,630 $229,915,987 $3,434,187 $388,329,804

2017 $117,541,968 $213,962,146 $3,269,886 $332,774,000

SOURCE: Trust Company Prepared Call Reports

Page 66 of 84

Financial Regulation Annual Report 2023

FIGURE 22. BANKS, CREDIT UNIONS, AND TRUST COMPANIES

Activity on Select Applications Fiscal Year Ending June 30, 2023

MERGERS and ACQUISITIONS

Surviving Institution

Main Location

Merged/Acquired Institution

Main Location

Approval

Summit Community Bank

Moorefield, WV

Provident State Bank

Preston, MD

02/24/2023

Summit Financial Group, Inc.

Moorefield, WV

PSB Holding Corp.

Preston, MD

02/24/2023

Shore United Bank N.A.

Easton, MD

The Community Bank of the Chesapeake

Waldorf, MD

03/07/2023

Shore Bancshores, Inc.

Easton, MD

The Community Financial Corporation

Waldorf, MD

03/07/2023

LINKBANCORP, Inc.

Camp Hill, PA

Partners Bancorp

Salisbury, MD

06/16/2023

MARYLAND CHARTER CONVERSION (TO A STATE-CHARTERED COMMERCIAL BANK)

Institution Name

Main Location

Action Approval

BayVanguard Bank

Baltimore, MD

Converted from a Maryland state-chartered

savings bank to a Maryland state-chartered

commercial bank.

07/21/2023

BV Financial, Inc.

Baltimore, MD

Merger of Bay-Vanguard, M.H.C., Inc. into BV

Financial, Inc. effectuated the conversion of

BayVanguard Bank’s bank holding company

from a mutual holding company to a stock

form holding company.

Pending

AFFILIATE FORMATION

Institution Name

Main Location

Afliate Approval

First United Bank & Trust

Oakland, MD

Investment Adviser Firm 01/12/2023

SOURCE: OFR Prepared Snapshot of Select Corporate Activities Applications

Page 67 of 84

Financial Regulation Annual Report 2023

FS 1. Summary of All Office Revenues and Expenditures Page 68

FS 2. Revenues and Expenditures – General Fund Page 69

FS 3. Revenues and Expenditures – Bank, Credit Union and Non-Depository Trust Company Special Fund Page 70

FS 4. Revenues and Expenditures – Non-Depository Special Fund Page 71

FS 5. Revenues and Expenditures – Foreclosed Property Registry Special Fund Page 72

FS 6. Revenues and Expenditures – Mortgage Foreclosure Mediation Special Fund Page 73

Financial Statements

APPENDIX B:

Page 68 of 84

Financial Regulation Annual Report 2023

FS 1. Summary of All Office Revenues and Expenditures

Fiscal Years Ended June 30th

* OFR has not been charged for parking since its move to the Maryland Dept. of Labor building on

Eutaw Street in February 2022.

REVENUES FY 2023 FY 2022 FY 2021

Special Funds

Banking and Credit Union $4,991,401 $5,049,103 $4,683,968

Non-Depository $10,016,573 $12,151,743 $10,943,547

Subtotal $15,007,974 $17,200,846 $15,627,515

Foreclosure-Related Special Funds

Mortgage Foreclosure Mediation $0 $0 $8,205

Foreclosed Property Registry $155,592 $74,818 $80,923

Subtotal $155,592 $74,818 $89,128

General Funds

Licensing Fees $0 $0 $0

Fines & Penalties $183,876 $185,293 $152,946

Miscellaneous $500 -$2,660 $150

Subtotal $184,376 $182,633 $153,096

Total Revenue $15,347,942 $17,458,297 $15,869,739

EXPENDITURES FY 2023 FY 2022 FY 2021

Salaries and Benefits $10,060,069 $9,072,836 $8,259,770

Technical and Special Fees $914,180 $802,366 $775,987

Communication $100,512 $83,184 $48,853

Travel/Training $121,052 $41,574 $17,331

Lease Expense, Parking Facilities* $0 $53,700 $73,536

Contractual Services $569,371 $370,159 $281,184

Supplies and Materials $23,937 $27, 238 $26,710

Equipment $85,285 $27,206 $47,336

Fixed Charges, Rent $222,804 $287,642 $367,060

Administrative Expenses $1,701,021 $1,576,861 $1,432,305

Prior year accruals/encumbrance liquidations $35,565 $10,827 $0

Total Expenditures $13,833,795 $12,353,594 $11,330,071

Net Revenue for Fiscal Year $1,514,146 $5,104,703 $4,539,668

Page 69 of 84

Financial Regulation Annual Report 2023

FS 2. Revenues and Expenditures – General Fund

Fiscal Years Ended June 30th

REVENUE FY 2023 FY 2022 FY 2021

Non-Depository Licensing Fees $0 $0 $0

Fines & Penalties * $183,876 $185,293 $152,946

Miscellaneous $500 -$2,660 $150

Total Revenue $184,376 $182,633 $153,096

* All Fines & Penalties from all Programs are paid into the State’s General Fund.

EXPENDITURES FY 2023 FY 2022 FY 2021

Salaries and Benefits $0 $0 $0

Technical and Special Fees $6,251 $28,361 $130,946

Communication $0 $0 $1

Travel/Training $0 $0 $0

Contractual Services $0 $0 $0

Supplies and Materials $0 $0 $0

Equipment $0 $0 $2,748

Total Expenditures $6,251 $28,361 $133,695

Net Revenue for Fiscal Year $178,125 $154,272 $19,402

Page 70 of 84

Financial Regulation Annual Report 2023

FS 3. Revenues and Expenditures – Bank, Credit Union and Non-Depository Trust Company Special Fund

Fiscal Years Ended June 30th

* OFR has not been charged for parking since its move to the Maryland Dept. of Labor building on

Eutaw Street in February 2022.

REVENUE FY 2023 FY 2022 FY 2021

Bank and Credit Union Assessments $4,768,597 $4,832,226 $4,465,959

Non-Depository Trust Company Assessments $205,062 $208,537 $200,489

Depository Amendment and Filing Fees $17,742 $8,340 $17,520

Miscellaneous Income/Other $0 $0 $0

Total Revenue $4,991,401 $5,049,103 $4,683,968

EXPENDITURES FY 2023 FY 2022 FY 2021

Salaries and Benefits $2,669,083 $2,662,958 $2,257,087

Technical and Special Fees $447,080 $422,269 $371,009

Communication $18,845 $22,385 $11,313

Travel/Training $13,517 $14,780 $10,054

Lease Expense, Parking Facilities* $0 $5,975 $7,8 84

Contractual Services $5,819 $4,490 $5,053

Supplies and Materials $11,691 $14,645 $12,083

Equipment $0 $630 $64,904

Fixed Charges, Rent $60,908 $141,133 $135,764

Administrative Expenses $459,661 $448,103 $359,844

Prior year accruals/encumbrance liquidations $0 -$1,979 $0

Total Expenditures $3,686,605 $3,735,390 $3,234,995

Net Revenue for Fiscal Year $1,304,796 $1,313,713 $1,448,973

Special Fund Balance Carried Forward $11,193,914 $9,889,117 $8,575,405

Page 71 of 84

Financial Regulation Annual Report 2023

FS 4. Revenues and Expenditures – Non-Depository Special Fund

Fiscal Years Ended June 30th

* OFR has not been charged for parking since its move to the Maryland Dept. of Labor building on

Eutaw Street in February 2022.

REVENUE FY 2023 FY 2022 FY 2021

Non-Depository License Fees $9,498,184 $11,804,183 $10,393,066

Non-Depository Examination Fees $518,389 $303,742 $286,657

Miscellaneous Income/Other $0 $43,818 $263,824

Total Revenue $10,016,573 $12,151,743 $10,943,547

EXPENDITURES FY 2023 FY 2022 FY 2021

Salaries and Benefits $7,272,075 $6,355,425 $5,919,097

Technical and Special Fees $460,812 $349,035 $325,357

Communication $45,054 $50,056 $25,472

Travel/Training $107,125 $28,057 $2,551

Lease Expense, Parking Facilities* $0 $51,830 $65,238

Contractual Services $489,284 $262,688 $21,012

Supplies and Materials $12,226 $15,547 $12,065

Equipment $85,285 $26,844 $45,616

Fixed Charges, Rent $161,896 $226,734 $225,927

Administrative Expenses $1,083,409 $1,011,388 $879,606

Prior year accruals/encumbrance liquidations $35,565 -$4,406 $0

Total Expenditures $9,752,732 $8,373,498 $7,521,940

Net Revenue for Fiscal Year $263,841 $3,778,245 $3,421,607

Special Fund Balance Carried Forward $18,944,795 $18,680,954 $14,902,709

Page 72 of 84

Financial Regulation Annual Report 2023

FS 5. Revenues and Expenditures – Foreclosed Property Registry Special Fund

Fiscal Years Ended June 30th

NOTE: The Foreclosed Property Registry Special Fund (FS 5) includes unreimbursed expenses from Maryland DHCD

for foreclosure outreach mailings, which would have been shown in the Mortgage Foreclosure Mediation

Special Fund (FS 6) for FY22 and FY23.

REVENUE FY 2023 FY 2022 FY 2021

Foreclosure Registrations $126,550 $69,950 $76,250

Miscellaneous Income/Other $29,042 $4,868 $4,673

Total Revenue $155,592 $74,818 $80,923

EXPENDITURES FY 2023 FY 2022 FY 2021

Salaries and Benefits $118,910 $48,328 $83,586

Special and Technical $37 $0 $0

Communication $36,613 $14,283 $994

Travel/Training $409 $0 $0

Lease Expense, Parking Facilities* $0 $1,870 $2,323

Contractual Services $74,268 $101,652 $255,681

Supplies and Materials $20 $0 $0

Equipment $0 $362 $1,090

Fixed Charges, Rent $0 $0 $0

Administrative Expenses $157,951 $105,513 $104,596

Prior year accruals/encumbrance $0 $17, 212 0

Total Expenditures $388,208 $289,220 $448,271

Net Revenue for Fiscal Year -$232,616 -$214,402 -$367,348

Special Fund Balance Carried Forward $787,226 $1,019,842 $1,234,243

* OFR has not been charged for parking since its move to the Maryland Dept. of Labor building on

Eutaw Street in February 2022.

Page 73 of 84

Financial Regulation Annual Report 2023

FS 6. Revenues and Expenditures – Mortgage Foreclosure Mediation Special Fund

Fiscal Years Ended June 30th

NOTE: Reimbursement from Maryland DHCD for foreclosure outreach mailings was temporarily suspended

due to decreased foreclosure activity, as DHCD was not collecting ling fees during the foreclosure

moratorium. OFR continued sending outreach letters to homeowners, notwithstanding the interruption

in reimbursement. During FY22 and FY23 expenses related to foreclosure outreach mailings were being

charged to the Foreclosed Property Registry Special Fund (FS 5). OFR expects reimbursements to resume

in FY24, at which time expenses will be reported in the Mediation Special Fund.

REVENUE FY 2023 FY 2022 FY 2021

Miscellaneous Income/Other (Reimbursed) $0 $0 $8,205

Accrued revenue $0 $0 $0

Total Revenue $0 $0 $8,205

EXPENDITURES FY 2023 FY 2022 FY 2021

Communication $0 $0 $0

Contractual Services $0 $0 $0

Supplies and Materials $0 $0 $0

Administrative Expenses $0 $0 $0

Total Expenditures $0 $0 $0

Net Revenue for Fiscal Year $0 $0 $8,205

Special Fund Balance Carried Forward $0 $0 $0

Financial Regulation Annual Report 2023 Page 74 of 84

Page 75 of 84

Financial Regulation Annual Report 2023

Commissioners as of June 30, 2023 Page 76

Deputy Commissioners as of June 30, 2023 Page 77

Historical Lists of Commissioners and Deputy Commissioners

APPENDIX C:

Page 76 of 84

Financial Regulation Annual Report 2023

Commissioners as of June 30, 2023

NAME FROM TO

Antonio P. Salazar 2017 Present

Gordon M. Cooley 2014 2017

Mark A. Kaufman 2010 2014

Sarah Bloom Raskin 2007 2010

Charles W. Turnbaugh 2003 2007

Mary Louise Preis 1999 2003

H. Robert Hergenroeder * 1996 1999

Margie H. Muller 1983 1996

Joseph R. Crouse 1980 1983

W. H. Holden Gibbs 1978 1980

William L. Wilson 1971 1978

William A. Graham 1967 1971

Herbert R. O'Conor, Jr. 1963 1967

W. R. Milford 1960 1963

William F. Hilgenberg 1959 1960

William H. Kirkwood, Jr. 1951 1959

Joseph P. Healy 1950 1951

J. Millard Tawes 1947 1950

John W. Downing 1939 1947

Warren F. Sterling 1935 1939

John J. Ghingher 1933 1935

George W. Page 1919 1933

J. Dukes Downs 1910 1919

* In 1996, the Bank Commissioner’s Office was merged by statute with the Office

of Consumer Credit, resulting in the change of titles from Bank Commissioner and

Deputy Bank Commissioner of Financial Regulation to Commissioner and Deputy

Commissioner of Financial Regulation respectively.

Page 77 of 84

Financial Regulation Annual Report 2023

Deputy Commissioners as of June 30, 2023

NAME FROM TO

Vacant 2023 Present

Gregory K. Thoreson 2021 2023

Teresa M. Louro 2016 2021

Keisha L. Whitehall Wolfe (Acting) 2014 2015

Gordon M. Cooley 2013 2014

Anne Balcer Norton 2010 2013

Mark A. Kaufman 2008 2010

Joseph E. Rooney 2003 2008

Nerry L. Mitchell 1999 2003

William L. Foster * 1996 1999

David M. Porter 1993 1996

Henry L. Bryson 1987 1993

Charles R. Georgius 1979 1987

Charles A. Knott, Jr. 1977 1979

Albert E. Clark 1972 1977

H. Sadtler Nolen 1967 1972

John D. Hospelhorn 1923 1967

John J. Ghingher 1919 1923

George W. Page 1912 1919

John C. Motter 1910 1912

* In 1996, the Bank Commissioner’s Office was merged by statute with the Office

of Consumer Credit, resulting in the change of titles from Bank Commissioner and

Deputy Bank Commissioner of Financial Regulation to Commissioner and Deputy

Commissioner of Financial Regulation respectively.

Office of Financial Regulation

Maryland Department of Labor

1100 North Eutaw Street, Suite 611,

Baltimore, MD 21201

410-230-6100 | Toll-free: 1-888-784-0136

DLFRFinReg-LABOR@maryland.gov

Visit us at Visit us at

www.labor.www.labor.

maryland.gov/maryland.gov/

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