Frequently Asked Questions: Maryland Credit Services Business - Financial Regulation
Last reviewed/updated: September 16, 2026
This FAQ provides guidance for determining whether a Credit Services Business (CSB) license is required to conduct business in Maryland. This FAQ is intended as a general informational resource and is not a substitute for legal advice or a formal licensing determination.
Whether a company needs a CSB license under Maryland’s Credit Services Business Act (CSBA) depends on the specific activities the company performs. The Office of Financial Regulation (OFR)evaluates licensing requirements based on the facts and circumstances of each business model. Companies should consult legal counsel to review their operations and business plans and determine whether any Maryland licensing requirements may apply. Companies may also contact OFR for a formal license determination.
- What is a Credit Services Business (CSB)?
A CSB is any person or company that, for compensation, offers to improve a consumer’s credit or assists them in obtaining credit from a third party. Some examples include:
- Improving a consumer’s credit record, history, or rating
- Obtaining an extension of credit for a consumer, or assisting a consumer in obtaining an extension of credit
- Referring consumers to lenders or loan products
- Matching consumers with lenders online
- Giving advice on improving credit scores or how to obtain a loan
- Forwarding a loan application to a lender on behalf of a consumer
- Assisting a consumer in locating finance options, including options related to retail purchases
- My company doesn’t lend money. Do we still need a license?
- What if we just provide software or a platform for others to make loans?
If your software or platform facilitates the extension or offering of credit, or helps consumers access loans, and you receive compensation, you may need a CSB license. Platform operators should carefully assess their role and seek legal advice. Companies with questions regarding a specific business model are also encouraged to contact OFR for guidance.
- We are a fintech company partnering with a bank. We do not extend credit ourselves, the bank does. Do we still need a CSB license?
Possibly. The determination depends on the specific activities performed by your company.
Even if a bank or lender extends the credit, your company may require a CSB license if it helps consumers obtain credit (see Question 1). Licensure is based on your company’s role in helping consumers obtain credit, not on who funds or originates the loan.
- My company works directly with retailers that offer financing options to consumers. We do not have a relationship with lenders. Do we need a CSB license?
If your company offers any of the services identified by the CSBA, your company will likely require a CSB license. Whether your company is a CSB is not based on whether your company works directly with lenders, retailers, or any other party. The products and services your company offers determine whether your company is a CSB.
- If we are only providing technology, software, or underwriting tools to a lender, are we exempt from licensure?
If your company only provides back-end software services to a lender and does not interact with consumers, market loan products, refer borrowers, or receive compensation tied to loan origination or placement, a CSB license might not be required. However, licensing determinations depend on the totality of the facts and circumstances. If your platform or activities involve consumer-facing engagement, referral activity, credit matching, or compensation connected to your assistance, licensure may be required.
Companies should carefully evaluate their business model and seek legal counsel or contact OFR if there is uncertainty.
- We’re based outside Maryland. Do these rules still apply to us?
Yes. If you advertise to Maryland residents or your services are accessible to Maryland residents (including online), the CSBA applies. Physical presence in Maryland is not required for jurisdiction.
- We run a lead generation site and send loan leads to lenders. Do we need a license?
Yes, likely. Lead generation that results in compensation, whether paid by a lender, affiliate network, or another party, can fall under the CSBA and require a license.
- What counts as “compensation”?
Compensation includes:
- Direct payments from consumers
- Per-lead or per-loan payments from lenders
- Affiliate marketing revenue
- Back-end fees or commissions
Note that the law’s scope of “compensation” is not limited to compensation received directly from consumers. If you’re getting paid in connection with helping consumers access credit, whether directly by the consumer or by a third party, that’s likely compensation triggering the CSBA.
- Are there any exemptions from CSB licensure?
Yes. The CSBA contains several statutory exemptions. Examples include:
- Banks eligible for FDIC insurance
- Federal or Maryland chartered credit unions
- Mortgage lenders licensed in Maryland
- Maryland licensed real estate brokers and salesperson acting within the scope of their licenses
- Maryland licensed attorneys and certified public accountants acting within the scope of their practice and not regularly engaged in the credit services business
- Nonprofit organizations under 26 U.S.C. §501(c)(3)
These examples are not intended to be a complete list of exemptions. Companies should review the CSBA for the full list of statutory exemptions and consult legal counsel or OFR if they are unsure whether an exemption applies.
- We're already licensed under another provision of the Md. Financial Institutions Code. Are we exempt?
Not necessarily. Whether a separate Maryland license creates an exemption under the CSBA depends on the specific activities your company performs and whether a statutory exemption applies.
For example, the CSBA does not contain a statutory exemption for companies engaged in money transmission. Accordingly, a company that holds a money transmission license and also engages in credit services business activities may still require a CSB license.
In contrast, Maryland Commercial Law § 14-1901(e)(3)(i) generally excludes companies that are authorized to make loans or extend credit and are actively engaged in those activities.
If you hold another Maryland financial services license, you should seek counsel or contact our Office to determine whether a separate CSB license is required.
- What are the consequences of operating without a license?
Consequences may include:
- Administrative or civil penalties
- Restitution to consumers
- Cease and desist orders
- Criminal penalties in certain circumstances
Additional remedies and enforcement authority may be available under Maryland law depending on the facts and circumstances.
- How can we initially determine if we need a license?
Start by reviewing:
- Do you assist consumers in obtaining loans or improving credit?
- Do you offer platforms or software to improve credit for consumers or match consumers with lenders?
- Do you get paid when a loan is made or referred?
If the answer to one or more of these questions is “yes,” your activities likely fall within the scope of the CSBA. Companies should evaluate their business model carefully and seek legal counsel or contact OFR if there is uncertainty regarding licensing requirements.
- Where can we find out more about the requirements under Maryland’s Credit Services Business Act?
Applicants and licensees are expected to understand and comply with applicable Maryland law, including the Maryland Credit Services Businesses Act which can be found in Maryland Code, Commercial Law Article, Title 14, Subtitle 19.
You can also visit OFR’s Industry Resources page to learn more about the CSBA.
This FAQ is intended as a general educational resource and should not be relied upon as a substitute for reviewing the statute, obtaining legal advice, or requesting a formal license determination from OFR.
Seek Guidance on Next Steps
If you are uncertain as to whether your activities fall within the scope of Maryland’s Credit Services Business Act, we encourage you to contact our Office before offering services to Maryland residents.
OFR regularly reviews business models and provides guidance and license determinations based on specific facts and circumstances. Early engagement helps ensure compliance and avoids potential disruption to your business.
We are committed to providing clear, consistent guidance and welcome questions from companies seeking to understand their obligations under Maryland law.
These FAQs address the CSBA and its licensing requirements. If a company’s activities do not require a CSB license, those activities could trigger a requirement for other licenses issued by the OFR, such as a consumer lending license, an installment lending license, a debt management services license, a debt settlement services license, or a collection agency license.
Contact
For questions about this advisory or to request a license determination under Maryland’s Credit Services Business Act, please contact Clifford Charland, Assistant Commissioner, Financial Services Licensing and Supervision by phone at 410-230-6167 or by email at [email protected].
Companies interested in discussing new or innovative business models, market entry in Maryland, or OFR’s approach to responsible innovation may contact Shereefat Balogun, Assistant Commissioner for Innovation by phone at 410-230-6390 or by email at [email protected].
Yes, possibly. The CSBA does not condition the definition of a CSB on lending money or servicing loans. If your business assists consumers in getting loans or offers credit-related services andreceives compensation, you may need a CSB license even if you’re not a lender.