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US-MD (US-MD) · Module W1b · Derived Confidence: Probable

US-MD: Conduct, Safeguarding & Financial Promotions

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Maryland's conduct regime for EWA moves from HB1294 (2025, tipping permitted with disclosure) to SB94 (2026, tipping banned), effective October 1, 2026.

Horizon · 2026-10-01 In force (commenced)SB94 Earned Wage Access tipping ban in forceIn force (commenced)
Standing sub-brief · as of 5 July 2026160 words · last cycle 2026-07-05

Conduct, Safeguarding & Financial Promotions

Maryland's core consumer-fund safeguarding mechanism for money transmitters is a surety bond rather than a trust or segregation model: a minimum $150,000 bond, scaling to $1,000,000 with transmission volume, stands in place of asset segregation. Conduct requirements tightened substantially this cycle. Senate Bill 94, signed April 28, 2026, bans tipping in earned wage access products and mandates overdraft-fee reimbursement, though it does not take effect until October 1, 2026 — HB1294 (2025), which permits disclosed tipping, remains the operative regime until then. Finalized Virtual Currency Kiosk rules under COMAR 09.03.16, effective January 13, 2026, impose disclosure-timing, receipt-content, ATM-style physical-safety, sanctioned-wallet screening, and chief-compliance-officer designation requirements on kiosk operators.

Outlook

The conduct layer is escalating on two tracks: the EWA tipping ban's October 2026 in-force date is the operative milestone to track rather than the April signing date, and the kiosk conduct rules' sanctioned-wallet screening requirement creates a direct operational link to this jurisdiction's AML/CFT posture.

no periodic updates on record for this sub-brief

Sources and findings (5 unique sources · R-3/R-4)
  1. [W1b-E1] T3 Derived: Probable in_forcehttps://suretygroup.com/surety-bond/maryland-money-transmitter-bond/ re-verified

    A minimum $150,000 surety bond is required for Maryland money transmitters and may increase up to $1 million based on the volume of transmissions, acting as the state's principal consumer safeguarding mechanism in lieu of a trust/segregation model.

  2. [W1b-E2] T3 Derived: Probable draft_no_legal_forcehttps://www.consumerfinancialserviceslawmonitor.com/2026/05/maryland-enacts-sweeping-earned-wage-access-reforms-bans-tipping/ re-verified

    Senate Bill 94, signed April 28, 2026, eliminates tipping in the EWA context, requires clear disclosure that providers are prohibited from soliciting or retaining tips, and mandates reimbursement of overdraft fees within five business days caused by a provider's attempted collection.

  3. [W1b-E3] T3 Derived: Probable in_forcehttps://www.sheppard.com/insights/blogs/maryland-finalizes-comprehensive-rules-governing-virtual-currency-kiosks re-verified

    Finalized January 13, 2026 kiosk regulations impose minimum on-screen disclosure timing, extensive receipt content requirements, ATM-like lighting and safety standards, wallet-use restrictions, sanctioned-wallet screening via blockchain analytics, and a designated chief compliance officer.

  4. [W1b-E4] T3 Derived: Probable in_forcehttps://www.goodwinlaw.com/en/insights/publications/2025/05/alerts-finance-ftec-maryland-enacts-law re-verified

    Providers must offer at least one reasonable no-cost method for consumers to access wages, may not obtain credit reports to qualify consumers, and may not report failure to pay to a consumer reporting agency or pursue civil collection action.

  5. [W1b-E5] T1 Derived: Confirmed in_forcehttps://labor.maryland.gov/finance/advisories/advisory-cryptocurrencyconsumer.pdf re-verified

    The Maryland Commissioner of Financial Regulation issued a consumer advisory warning that cryptocurrencies are not insured by the government, are not deposits, and are not federally insured by the FDIC or NCUA, framing the state's conduct posture toward crypto-payment products.