Addressing a certified question from the U.S. District Court for the District of Maryland, a majority of the Maryland Court of Appeals held that a law firm that engages in debt collection activities on behalf of a client is not subject to the provisions of the Maryland Consumer Loan Law.

Nagle & Zaller, a Columbia, Maryland, firm that provides legal services and debt collection services for homeowner associations, was retained by them in negotiating and drafting promissory notes with homeowners that memorialized repayment terms of delinquent assets.