State Regulatory Developments

Maryland Replaces its Foreclosed Property Registry

On December 31, 2018, the Maryland Commissioner of Financial Regulation provided an advisory notice clarifying how Maryland would replace its current online Foreclosed Property Registry with the Foreclosure Registration System.  Through the system, users will be able to submit initial and final foreclosed property registrations, update initial foreclosed property registrations, and transfer initial and final foreclosed property registrations between company accounts.

Effective January 1, 2019, Maryland law requires a foreclosure purchaser to submit to the Internet-based registry established by the Maryland Department of Labor, Licensing, and Regulation any change to certain information in an initial registration within 21 business days after the change is known to the purchaser.  (WBK’s previous summary of this requirement may be found here.)  The Department’s registry for purposes of this requirement previously was the Foreclosed Property Registry, which registry will be phased out by the end of January 2019.

The new Foreclosure Registration System, which has an integrated foreclosure registry, began accepting foreclosed property registrations as of January 2, 2019, and as of that date, all initial foreclosed property registrations must be submitted using the new system.  To incorporate the new requirements under Maryland law and to upgrade the old registry database and user account structure, the Commissioner began migrating the data in the Foreclosed Property Registry to the new Foreclosure Registration System, which process it expects to complete before the end of January 2019.  Until the migration process is implemented, users will continue to have access to their property registrations in the legacy registry and be able to submit a final registration for initial registration in the legacy registry.

Per a previous advisory notice from the Commissioner, users of the new Foreclosure Registration System are required to create a user account, notwithstanding that a user may already have an account with the legacy registry.

The advisory notice on the change of online registry, which includes a link to the updated user guide, may be found here.

Previous advisory notices regarding the new registry may be found here and here.