title: US-MD — Consumer Protection & APP Fraud (W10) | World Payments Monitor canonical: https://payments.gi/jurisdictions/united-states-maryland/w10/ ### W10 Consumer Protection & APP Fraud Probable re-verified 2026-10-18 · changed 2026-07-05 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 2026 135 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× uses https://labor.maryland.gov/whatsnews/govmooresignsearnedwageaccessandaccesstobankingbills.shtml](https://labor.maryland.gov/whatsnews/govmooresignsearnedwageaccessandaccesstobankingbills.shtml) re-verified 2026-07-05 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_force https://www.labor.maryland.gov/finance/banks/access-to-banking.shtml](https://www.labor.maryland.gov/finance/banks/access-to-banking.shtml) re-verified 2026-07-05 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_force https://www.sheppard.com/insights/blogs/maryland-finalizes-comprehensive-rules-governing-virtual-currency-kiosks](https://www.sheppard.com/insights/blogs/maryland-finalizes-comprehensive-rules-governing-virtual-currency-kiosks) re-verified 2026-07-05 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_force https://oag.maryland.gov/i-need-to/Pages/Guidelines-for-Businesses-to-Comply-with-the-Maryland-Personal-Information-Protection-Act.aspx](https://oag.maryland.gov/i-need-to/Pages/Guidelines-for-Businesses-to-Comply-with-the-Maryland-Personal-Information-Protection-Act.aspx) re-verified 2026-07-05 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.