NVR Mortgage Finance, Inc. v. Carlsen, 96 A.3d 202

In 2004, Carlsen and NVR entered a contract for building a home; NVR Mortgage would obtain financing for Carlsen.
Carlsen applied for a mortgage from NVR Mortgage but the loan did not close; later Carlsen obtained a mortgage from C&F Mortgage Corp.
In 2005, Carlsen and C&F closed on the mortgage and Carlsen paid a finder’s fee to NVR Mortgage.
More than three but fewer than twelve years later, Carlsen sued NVR for alleged violations of CL § 12-805(d) in Baltimore County Circuit Court.
NVR removed to federal court, which certified a question of law to this Court; this Court reformulated and answered that CL § 12-805(d) is not an “other specialty” and is subject to a three-year statute of limitations.
The Finder’s Fee Act contains no statute of limitations; the default three-year period applies unless an “other specialty” is found under CJP § 5-102(a)(6).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether CL § 12-805(d) is an 'other specialty' under CJP § 5-102(a)(6).	Carlsen argues the duty and remedy are created solely by the FFA, fitting the 'other specialty' criteria.	NVR argues the duty exists at common law or the Defendant did not intend to create an ‘other specialty’ with CL § 12-805(d).	No; CL § 12-805(d) is not an 'other specialty' and is governed by the three-year limit.

AGV Sports Grp., Inc. v. Protus IP Solutions, Inc., 417 Md. 389 (Md. 2010) (MTCPA not an 'other specialty' because damages are not readily ascertainable; common law actions address the same duty.)
Crowder v. Master Fin., Inc., 409 Md. 51 (Md. 2009) ('Other specialty' requires distinct statutory duty and remedy; broad catchall limited.)
St. Paul at Chase Corp. v. Mfrs. Life Ins. Co., 262 Md. 192 (Md. 1971) (Common law duties may underlie statutory disclosures.)
Greene Tree Home Owners Ass’n, Inc. v. Greene Tree Assocs., 358 Md. 453 (Md. 2000) (Post-CJP 5-101/5-102 analysis; statutory remedies not always ‘other specialty’.)