Editors' Summary: The trend in cases deciding CERCLA landowner liability has been to increase the situations in which liability arises. Lending institutions' liability for cleanup costs and remedial action at hazardous waste sites for which they have made loans to property owners is the most recent area of dispute. The recent decision in United States v. Maryland Bank & Trust Co. has caused the banking industry to sit up and take notice of CERCLA landowner liability. Contrary to another recent district court decision, United States v. Mirabile, the Maryland court ruled that CERCLA §101(20), which excludes one holding title to protect a security interest from the definition of "owner" subject to landowner liability, does not apply after the lending institution has foreclosed on a property. As a landowner, the bank will have the opportunity, however, to make out the affirmative defenses allowed in §107(b). The author compares the two contrary cases and concludes that the results may be reconciled. He analyzes the potential impacts of Maryland Bank & Trust on banks' future loans for property that may contain hazardous wastes and discusses the usefulness of CERCLA's third-party defense to bankers facing liability.