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US-MD (US-MD) · Module W10 · Derived Confidence: Probable

US-MD: Consumer Protection & APP Fraud

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Maryland's 2025-26 legislative program substantially expanded payments-adjacent consumer protection, closing regulatory loopholes for app-based earned-wage-access 'payday loans,' expanding the Access to Banking Act to reach underbanked consumers directly, and building fraud-refund and disclosure mechanics into the new virtual currency kiosk regime. The Attorney General's Consumer Protection Division and OFR share enforcement.

Standing sub-brief · as of 5 July 2026135 words · last cycle 2026-07-05

Consumer Protection & APP Fraud

SB94, signed April 28, 2026 and in force October 1, 2026, closes app-based payday-loan-style loopholes in earned wage access products; a 2024 Market Inquiry had found Maryland consumers paid more than $35 million in fees on 5.5 million EWA transactions between 2019 and 2024, with dark-pattern tip pricing averaging more than $280 per user. The 2023 Access to Banking Act was expanded in 2026 via SB43/HB259 to create a collaborative model and Maryland Opportunity Accounts, channeling fee credits to banks and credit unions that bring unbanked and underbanked residents into the formal financial system.

Outlook

Consumer protection is the most escalating tracker in this cycle's Maryland output: the EWA fee-and-tipping evidence base is strong, but the reform's practical effect will not be testable until the October 2026 in-force date passes.

no periodic updates on record for this sub-brief

Sources and findings (4 unique sources · R-3/R-4)
  1. [W10-E1] T1 Derived: Confirmed draft_no_legal_force Collapsed 2× useshttps://labor.maryland.gov/whatsnews/govmooresignsearnedwageaccessandaccesstobankingbills.shtml re-verified

    Governor Moore signed the Earned Wage Access bill (SB94) on April 28, 2026, closing regulatory loopholes for app-based payday loans; a 2024 Market Inquiry found Maryland consumers paid over $35 million in fees on 5.5 million EWA transactions between 2019 and 2024, with 'dark-pattern' tip pricing averaging more than $280 per user.

  2. [W10-E2] T1 Derived: Confirmed in_forcehttps://www.labor.maryland.gov/finance/banks/access-to-banking.shtml re-verified

    Governor Moore signed the Maryland Access to Banking Act into law on May 8, 2023, offering assessment credits to state-chartered banks and credit unions operating in low-to-moderate income communities and establishing a venture fund to invest in financial innovations serving those communities.

  3. [W10-E4] T3 Derived: Probable in_forcehttps://www.sheppard.com/insights/blogs/maryland-finalizes-comprehensive-rules-governing-virtual-currency-kiosks re-verified

    Finalized kiosk rules establish a structured process allowing users to request refunds of fees associated with allegedly fraudulent transactions, including defined timelines and investigation standards, with operators prohibited from requiring a police report to process claims.

  4. [W10-E5] T1 Derived: Confirmed in_forcehttps://oag.maryland.gov/i-need-to/Pages/Guidelines-for-Businesses-to-Comply-with-the-Maryland-Personal-Information-Protection-Act.aspx re-verified

    PIPA requires a business to notify the Office of the Attorney General before notifying consumers, and consumer notice must include toll-free numbers for credit reporting agencies, the FTC, and the Maryland OAG, plus a statement about identity-theft prevention steps.