Route two: no new board at all

The second bill is the one almost nobody covered, and it is the more interesting design.

HB 1644, Property Management Services – Licensing and Requirements, from Delegate Hill, would have avoided building an institution entirely. It proposed altering the definition of “provide real estate brokerage services” to include property management services — pulling managers under the existing State Real Estate Commission. It would have authorised the Commission to impose penalties on a licensee for violations of the Act's property-management provisions, and required licensees to complete continuing education on property management every two years.²

No new board, no new fee structure, no $224,600 in startup funding. The regulator, the licensing exam, the disciplinary process and the continuing-education machinery all already exist.

It also never got a hearing. Introduced late, it needed a rules suspension to be filed at all — adopted 104–20 on 10 March 2026 — was referred to Rules and Executive Nominations, rereferred to Economic Matters on 16 March, and died there. No hearing was ever scheduled.²

It was a first filing, and its procedural position was hopeless from the start: a bill that arrives in mid-March in a session ending 13 April is not going to be heard.

The double-regulation problem the fiscal note spotted

One detail in the HB 853 analysis deserves more attention than it received. The Department of Legislative Services noted that managers in Montgomery and Prince George's counties would have become regulated at both state and local levels.³

Those two counties run the state's only full common-ownership-community commissions, and both reach managers directly. Prince George's now requires management companies to register and pay $100 annually, and its March 2026 rules make the management company primarily responsible for document compliance — with fines up to $5,000 recoverable from the management contract as liquidated damages. A state licensing board on top of that is a second regulator over the same conduct.

This is the recurring structural obstacle for statewide Maryland community-association regulation: two large counties have already built their own, and anything statewide either duplicates them or has to be drafted around them. HB 402's oversight division had to include an express non-preemption clause for exactly this reason.

Four sessions, one chamber win

Manager licensing has been filed every session, and the record is consistent:⁴

• 2023 — HB 80. Died after a January hearing.
• 2024 — HB 273. Died after a February hearing.
• 2025 — HB 303. Passed the House, then died in the Senate after a 27 March hearing.
• 2026 — HB 853. Died in Economic Matters without a report.

2025 was the high-water mark, and 2026 went backwards: a bill that had cleared a chamber the year before did not get out of committee.

CAI's Maryland Legislative Action Committee opposed it, costing the proposal at over $100,000 in state funding.⁴ The fiscal note's own first-year figure was more than double that.

What actually governs a Maryland manager today

No licence, but not nothing. Three live constraints, all of them recent:

• The Attorney General's Consumer Protection Division. Since October 2025 it has enforcement jurisdiction over every violation of the Condominium Act and the HOA Act, and in December 2025 it obtained a Final Order against a management company over unlawful late fees carrying $1.3 million in civil penalties. Enforcement is not licensing, but it is consequence.
• The 2025 election law. Chapter 512 disqualifies a third-party management representative from acting as the independent party in an association election, unless the management company is owned by the community or its parent association. That is a statutory competence limit on managers imposed without a licensing scheme.
• County registration. Prince George's and Montgomery County both reach managers through their commissions.

Maryland has, in effect, chosen enforcement and local registration over occupational licensing — not by deciding to, but by repeatedly declining the alternative.

What to watch next

Whether the 2027 filing follows HB 853's design or HB 1644's. A bill that routes managers through the existing Real Estate Commission has no startup appropriation to defend and no new board to justify, which removes the objection that has been made against it in four consecutive sessions. Nobody has yet tested that version in a hearing, because HB 1644 never got one.

Pre-file drafting requests are due 20 November 2026; the 2027 session convenes 13 January 2027. A pre-filed bill gets a hearing. A bill filed in March does not.