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Supplemental Guidance on the Student Financing Company Act - Financial Regulation

November 9, 2026

The Office of Financial Regulation (OFR) is providing this supplemental guidance regarding the  Student Financing Company Act, 2023 House Bill 913 (the Act) following previous guidance for entities providing financing for post-secondary education expenses (a Student Financing Company or “SFC”). The Act is codified in Commercial Law Article §12-1101 et. seq, Annotated Code of Maryland. All statutory references contained herein are to the Commercial Law Article. This replaces all previous guidance. While OFR is providing this general guidance, entities should both read the legislation and consult with their own counsel as to the applicability of the Act.

OFR will also hold a webinar to further explain this information.

Date: Tuesday, December 1st
Time: 11:00 a.m. – 12:00 p.m. ET
Location: Virtual - Register NOW!

Responsibility to Register and Report

Every SFC is required to register with OFR and provide an annual report. The statute provides that any student financing product (typically a loan or payment plan for tuition) it offers shall be void and unenforceable where, after notice and hearing, the Commissioner finds the student financing company that either provided or acquired the product a resident of the State owes knowingly violated this subtitle at the time the product was provided or acquired or fails to comply with any registration or reporting requirement.

Registration

Standard SFCs are required to register using the Nationwide Multistate Licensing System (NMLS) Student Financing Company category. These SFCs must register as a Student Financing Company prior to providing any required data to OFR. If a higher education institution SFC is an Acquiring institution, they must register with NMLS. If a higher education institution SFC is a Lending SFC, they do not have to register with NMLS. See below for the difference between a Lending SFC and an Acquiring SFC. Lending SFCs that are higher education institutions must register with OFR using the Higher Education Student Financing Company Registration Form.

Submission

All SFCs, including higher education institutions, should use the annual reporting form for reporting required data, and include additional attachments as instructed in the form. Further instruction is found on the annual reporting form. Any SFC acting as both a Lending SFC and an Acquiring SFC should submit separate documents based on whether they extended the student financing product or acquired it. All information should be uploaded to Maryland Office of Financial Regulation - Student Financy Company Uploads by March 15.

Accessibility Requirements

OFR is required to post promissory notes (requirement XV) in a digitally accessible format on the Office’s website in compliance with the Americans with Disabilities Act (ADA) Title II, Maryland Non-Visual Access Clause and Web Content Accessibility Guidelines (WCAG, 2.1 Level AA). To that end, SFCs must provide a fully compliant PDF copy of the promissory note that does not require any additional remediation by OFR to meet these standards. Scanned documents that have not been remediated for accessibility concerns are insufficient.

Data Points to Provide

The Act requires SFCs to report certain information on student financing. Differences in reporting requirements apply based on whether the SFC secured, made, or extended the student financing (Lending SFCs) or acquired or assumed the student financing (Acquiring SFCs). Acquiring SFCs are required to report the same data points (though in some instances with slight modifications) as Lending SFCs, with the exception of requirements (X), (XI), and (XV) listed below. These exceptions are also noted in the annual reporting form.

SFCs that are higher education institutions are subject to the same reporting requirements as other SFCs, with the exception of NMLS registration as explained above.

For the purposes of consistency in reporting data among all SFCs, OFR interprets “fiscal year” to mean from July 1 of a given year to June 30 of the following year. The General Assembly made a point to specify the time frame (e.g., FY 26) for some of the questions, but not others. OFR advises that where the Act does not stipulate the fiscal year, unless otherwise noted herein, the information the SFCs provide OFR should not be limited to the information from the most recent fiscal year.

The following information follows the data points identified in Financial Institutions Code §12-1103(a)(1) for Lending SFCs. To avoid unnecessary duplication in this Advisory, the difference for Acquiring SFCs will be noted below as opposed to listing Acquiring SFCs separately:

  • Statutory Requirement I: A list of all schools attended by consumers who received student financing from the student financing company and resided within the State at the time of the transaction and whose debt is still outstanding, including student financing used to refinance an existing debt
    • Acquiring SFC Responsibility: §12-1103(a)2(i) also requires Acquiring SFCs to report this data for acquired or assumed student financing products.
    • OFR interpretation: The General Assembly did not limit the number of transactions or the time frame for this request. OFR interprets this requirement to call for the submission of a listing of all schools attended by student loan borrowers who: received student financing products; listed a Maryland address at the time of the transaction; and still had outstanding debt at the end of the most recent fiscal year. For purposes of standardization, the SFC shall provide both the name of each school and the Federal School Code.
  • Statutory Requirement II: The total outstanding dollar amount owed by consumers residing in the State who received student financing from the SFC
    • Acquiring SFC Responsibility: §12-1103(a)(2)(ii) combines the reporting required in §12-1103(a)(1)(ii) and (iii) and requires Acquiring SFCs to report this data for acquired or assumed student financing products.
    • OFR interpretation: The General Assembly did not limit the number of transactions or the time frame for this request. OFR interprets this requirement to mean the total number of student financing products outstanding as of June 30 for a given year, which must be reported by March 15 of the following year. SFCs who provide products for graduate or undergraduate schooling should provide three separate values for requirement (II):
      • one value for the total outstanding dollar amount owed by consumers residing in the State who received student financing from the SFC across all types of education (undergraduate, graduate, and any other type of education);
      • one value for the total outstanding dollar amount owed by consumers residing in the State who received student financing from the SFC for undergraduate education;
      • and one value for the total outstanding dollar amount owed by consumers residing in the State who received student financing from the SFC for graduate education.
  • Statutory Requirement III: The total number of student financing products owed by consumers residing in the State who received student financing from the student financing company
    • Acquiring SFC Responsibility: §12-1103(a)(2)(ii) combines the reporting required in §12-1103(a)(1)(ii) and (iii) and requires Acquiring SFCs to report this data for acquired or assumed student financing products.
    • OFR interpretation: The General Assembly did not limit the number of transactions or the time frame for this request. OFR interprets this requirement to mean the total number of student financing products outstanding as of June 30 for a given year, which must be reported by March 15 of the following year. SFCs who provide products for graduate or undergraduate schooling should provide three separate values for requirement (II):
      • one value for the total number of student financing products owed by consumers residing in the State who received student financing from the SFC across all types of education (undergraduate, graduate, and any other type of education);
      • one value for the total number of student financing products owed by consumers residing in the State who received student financing from the SFC for undergraduate education;
      • and one value for the total number of student financing products owed by consumers residing in the State who received student financing from the SFC for graduate education.
  • Statutory Requirement IV: The total outstanding dollar amount and number of student financing products owed by consumers who reside in the State, associated with each school identified under requirement (I)
    • Acquiring SFC Responsibility: §12-1103(a)2(iii) requires Acquiring SFCs to report this data for acquired or assumed student financing products.
    • OFR interpretation: The General Assembly did not limit the number of transactions or the time frame for this request. OFR interprets this to mean the total dollar amount and number of products outstanding associated with each school as of June 30 for a given year, which must be reported by March 15 of the following year. OFR expects the sum of total outstanding dollar amount and number of student financing products across all schools for requirement (IV) to be equal to requirements (II) and (III), respectively. If these values differ, please provide an explanation.
  • Statutory Requirement V: The total dollar amount of student financing products provided by the SFC to consumers who resided in the State in the prior fiscal year
    • Acquiring SFC Responsibility: §12-1103(a)(2)(iv) combines the reporting required in §12-1103(a)(1)(v) and (vi) and, requires Acquiring SFCs to report this data for acquired or assumed student financing products.
    • OFR interpretation: The data to be provided pursuant to this request is limited to the most recent fiscal year. Information reported by March 15, 2027, need only include FY 2025 (i.e., July 1, 2025 to June 30, 2026). SFCs must collect and report such information for each subsequent fiscal year by the March 15 deadline. SFCs who provide products for graduate or undergraduate schooling should provide three separate values for requirement (II):
      • one value for the total dollar amount of student financing products provided by the SFC to consumers who resided in the State in the prior fiscal year across all types of education (undergraduate, graduate, and any other type of education);
      • one value for the total dollar amount of student financing products provided by the SFC to consumers who resided in the State in the prior fiscal year for undergraduate education;
      • and one value for the total dollar amount of student financing products provided by the SFC to consumers who resided in the State in the prior fiscal year for graduate education.
  • Statutory Requirement VI: The total number of student financing products provided by the SFC to consumers who resided in the State in the prior fiscal year
    • Acquiring SFC Responsibility: §12-1103(a)(2)(iv) combines the reporting required in §12-1103(a)(1)(v) and (vi) and, requires Acquiring SFCs to report this data for acquired or assumed student financing products.
    • OFR interpretation: The data to be provided pursuant to this request is limited to the most recent fiscal year. Information reported by March 15, 2027, need only include FY 2026 (i.e., July 1, 2025 to June 30, 2026). SFCs must collect and report such information for each subsequent fiscal year by the March 15 deadline. SFCs who provide products for graduate or undergraduate schooling should provide three separate values for requirement (II):
      • one value for the total number of student financing products provided by the SFC to consumers who resided in the State in the prior fiscal year across all types of education (undergraduate, graduate, and any other type of education);
      • one value for the total number of student financing products provided by the SFC to consumers who resided in the State in the prior fiscal year for undergraduate education;
      • and one value for the total number of student financing products provided by the SFC to consumers who resided in the State in the prior fiscal year for graduate education.
  • Statutory Requirement VII: The total outstanding dollar amount and number of student financing products owed by consumers who resided in the State, associated with each school identified under requirement (1), that were provided in the prior fiscal year
    • Acquiring SFC Responsibility: §12-1130(a)(2)(v) requires Acquiring SFCs to report this data for acquired or assumed student financing products.
    • OFR interpretation: The data to be provided pursuant to this request is limited to the most recent fiscal year. Information reported by March 15, 2027, need only include FY 2026 (i.e., July 1, 2025 to June 30, 2026). SFCs must collect and report such information for each subsequent fiscal year by the March 15 deadline. If you report a school under (i) but the debt has since been satisfied or legally discharged, that data point should be listed with a “0.” OFR expects the total outstanding dollar amount and number of student financing products for requirement (VII) to be less than or equal to the respective values under requirement (IV). OFR also expects the sum of total outstanding dollar amount and number of student financing products across all schools for requirement (VII) to be less than or equal to requirements (V) and (VI), respectively. If these values differ, please provide an explanation.
  • Statutory Requirement VIII: The rate of default for consumers residing in the State who obtained student financing from the SFC, if applicable
    • Acquiring SFC Responsibility: §12-1103(a)(2)(vi) requires Acquiring SFCs to report this data for acquired or assumed student financing products.
    • OFR interpretation: To ensure the ability to compare rates of default between years, OFR interprets this requirement to mean the percent of student loan borrowers in the SFC’s loan portfolio who listed a Maryland address and who went into default in the most recent fiscal year for reporting by March 15 of the following year. SFCs must collect and submit such information for each subsequent fiscal year by the March 15deadline. For (viii) and (ix), if a loan went into default on June 1, 2026, and remains in default in subsequent years, such default is only reported in the March 15, 2027, annual report and not in the subsequent annual reports. However, if the loan is reinstated but a subsequent default occurs under the reinstated loan, the subsequent default should be reported for the fiscal year in which such default occurs.
  • Statutory Requirement IX: The rate of default for consumers residing in the State who obtained student financing from the SFC associated with each school identified under requirement (I), if applicable
    • Acquiring SFC Responsibility: §12-1103(a)(2)(vii) requires Acquiring SFCs to report this data for acquired or assumed student financing products.
    • OFR interpretation: To ensure the ability to compare rates of default between years, OFR interprets this requirement to mean the percent of student loan borrowers in the SFC’s loan portfolio who listed a Maryland address and attended each school identified in requirement (I) with outstanding debt that went into default in the most recent fiscal year for reporting by March 15 of the following year. Data reported by March 15, 2027, should therefore include only those loans listing a Maryland address for the borrower that went into default between July 1, 2025, and June 30, 2026. SFCs must collect and submit such information for each subsequent fiscal year by the March 15 deadline.
  • Statutory Requirement X: The range of initial interest rates for student financing products provided by the SFC to consumers who resided in the State in the prior fiscal year)
    • Acquiring SFC Responsibility: There is no corresponding reporting requirement for Acquiring SFCs.
    • OFR interpretation: The data to be provided pursuant to this request is limited to the most recent fiscal year. Information reported by March 15, 2027, need only include FY 2026 (i.e., July 1, 2025 to June 30, 2026). SFCs must collect and report such information for each subsequent fiscal year by the March 15 deadline.
  • Statutory Requirement XI: Of the total number of consumers who received student financing products under requirement (X), the number of consumers who received each rate identified under requirement (X)
    • Acquiring SFC Responsibility: There is no corresponding reporting requirement for Acquiring SFCs.
    • OFR interpretation: SFCs should provide three separate sheets of this data: one representing all student financing products, one representing undergraduate student financing products, and one representing graduate student financing products. OFR interprets this to be broken down by whole percentages. For example, if the SFC’s range is 3% – 6.99% then the SFC should report the number of consumers receiving rates falling into one of the following ranges:
      • 3% – 3.99%;
      • 4% – 4.99%;
      • 5% – 5.99%; and
      • 6% – 6.99%.
  • Statutory Requirement XII: The total dollar amount and number of student financing products provided in the prior fiscal year by the SFC to consumers who resided in the State at the time of the transaction and had a cosigner for the student financing product
    • Acquiring SFC Responsibility: §12-1103(a)(2)(viii) requires Acquiring SFCs to report this data for acquired or assumed student financing products but does not limit the data to the most recent fiscal year. Unlike Lending SFCs, Acquiring SFCs should not limit their reporting under (viii) to the prior fiscal year.
    • OFR interpretation: The data to be provided pursuant to this request is limited to the most recent fiscal year for Lending SFCs, but not for Acquiring SFCs. For Lending SFCs, information reported by March 15, 2027, need only include FY 2026 (i.e., July 1, 2025 to June 30, 2026). SFCs must collect and report such information for each subsequent fiscal year by the March 15 deadline.
  • Statutory Requirement XIII: The total dollar amount and number of student financing products provided by the SFC to consumers residing in the State used to refinance a prior student financing product or federal student loan in the prior fiscal year
    • Acquiring SFC Responsibility: §12-1103(a)(2)(ix) requires Acquiring SFCs to report this data for acquired or assumed student financing products but does not limit the data to the most recent fiscal year. Therefore, and unlike Lending SFCs, Acquiring SFCs should not limit their reporting under (ix) to the prior fiscal year.
    • OFR interpretation: The data to be provided pursuant to this request is limited to the most recent fiscal year for Lending SFCs, but not for Acquiring SFCs. For Lending SFCs, information reported by March 15, 2027, need only include FY 2026 (i.e., July 1, 2025 to June 30, 2026). SFCs must collect and report such information for each subsequent fiscal year by the March 15 deadline.
  • Statutory Requirement XIV: The total dollar amount and number of student financing products for which the SFC had sued to collect from a consumer residing in the State in the prior fiscal year
    • Acquiring SFC Responsibility: §12-1103(a)(2)(x) requires Acquiring SFCs to report this data for acquired or assumed student financing products.
    • OFR interpretation: The data to be provided pursuant to this request is limited to the most recent fiscal year. Information reported by March 15, 2027, need only include FY 2026 (i.e., July 1, 2025 to June 30, 2026). SFCs must collect and report such information for each subsequent fiscal year by the March 15 deadline.
  • Statutory Requirement XV: A copy of any model promissory note, agreement, contract, or other instrument used by the student financing company in the previous fiscal year to substantiate that a consumer owes a new debt to the student financing company
    • Acquiring SFC Responsibility: There is no corresponding reporting requirement for Acquiring SFCs.
    • OFR interpretation: Please provide an accessible PDF of the model note(s) in the most recent fiscal year. If the note hasn’t changed since a previous submission, please note that. Information reported by March 15, 2027, need only include FY 2026 (i.e., July 1, 2025 to June 30, 2026). SFCs must collect and report such information for each subsequent fiscal year by the March 15 deadline.
  • Statutory Requirement XVI: Any other information considered necessary by the Commissioner to assess the total size and status of the student financing market and well-being of consumers in the State
    • Acquiring SFC Responsibility: §12-1103(a)(2)(xi) contains an identical requirement for Acquiring SFCs.
    • OFR seeks the following information from all SFCs under requirement (XVI):
      • Volume Data:
        • The total number of unique consumers who received financing from the SFC for undergraduate education and resided in the State in the prior fiscal year
        • The total number of unique consumers who received financing from the SFC for graduate education and resided in the State in the prior fiscal year
      • Complaint and Customer Service Data:
        • Number of complaints received from consumers residing in the state in the prior fiscal year
        • Total calls received by month from consumers residing in the state in the prior fiscal year
        • Total calls received from consumers residing in the state that were answered by a live agent in the prior fiscal year
        • The median and mean number of minutes that consumers residing in the state waited to speak with a live agent in the prior fiscal year
        • Total full-time equivalent (FTE) call center employees (as of the last day of the prior fiscal year)
      • Fee Data:
        • The total dollar amount of fees—including setup, initiation, origination, application, underwriting, processing, credit reporting, late payment, insufficient funds, service, or other fees—collected in the prior fiscal year from consumers residing in the state
        • The total number of student financing products belonging to consumers residing in the state on which a fee was charged in the prior fiscal year
        • The total dollar amount and number of fees charged by fee category as applicable, including for setup, initiation, origination, application, underwriting, processing, credit reporting, late payment, insufficient funds, service, and other fees.
      • Debt Collection Data:
        • The total dollar amount of debt that the SFC turned over to the Maryland Central Collection Unit in the prior fiscal year
        • The total number of student financing products for which the SFC turned debt over to the Maryland Central Collection Unit in the prior fiscal year
        • The total dollar amount of debt that the SFC sold or assigned to another entity in the prior fiscal year
        • The total number of student financing products that the SFC sold or assigned in the prior fiscal year

Who should I contact if I have questions?

If you have any questions about the information you must report to OFR, or any other aspect of the Act please contact Amy Hennen, Student Loan Ombudsman, Office of Financial Regulation, by email at [email protected] or by phone at 410-230-6094.