The Court of Appeals of Maryland recently held, in an appeal involving four consolidated cases, that foreign statutory trusts that own delinquent mortgage loans are not required to obtain a collection agency license under the Maryland Collection Agency Licensing Act before substitute trustees can institute foreclosure actions against defaulting borrowers. In each case on appeal, the borrowers had defaulted on their mortgage loan and the lender had transferred the loan and all beneficial interest in the deed of trust as part of a securitized pool of mortgage loans to one of two foreign statutory trusts.

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