Except as required by a provision other than this title, a trust need not be evidenced by a trust instrument, but the creation of an oral trust and the terms of the oral trust may be established only by clear and convincing evidence.
Md. Code, Estates and Trusts § 14.5-406, under Article — Estates and Trusts.
Md. Code, Estates and Trusts § 14.5-406
Except as required by a provision other than this title, a trust need not be evidenced by a trust instrument, but the creation of an oral trust and the terms of the oral trust may be established only by clear and convincing evidence.