WILNER, J.
Maryland Code, §§ 15-701(a) and 15-703(a) of the State Government Article (SG) (2003 Supp.) require a lobbyist to file with the State Ethics Commission a registration statement for each client that has employed the lobbyist. Failure to file a required registration statement subjects the lobbyist to criminal sanctions. SG § 15-903.
[373]*373SG § 15-405(e) permits the Commission to revoke a registration if the Commission determines that, based on acts arising from lobbying activities, the lobbyist has been convicted of bribery, theft, or other crime involving moral turpitude. A complaint charging such a conviction must be initiated within two years after the date the conviction becomes final. Section 15-405(e) was enacted in 2001 and took effect November 1, 2001. Prior to then, there was no express authority in the law for the Commission to suspend or revoke a registration and no statement of grounds upon which a registration could properly be suspended or revoked.
On July 14, 2000, appellee, Gerard Evans, a registered lobbyist, was convicted in U.S. District Court on nine counts of wire and mail fraud arising out of his lobbying activities. On September 29, 2000, he was sentenced to 30 months imprisonment, fined, and required to pay restitution by reason of those convictions. As no appeal was taken, the conviction became final that day, some 13 months before § 15-405 took effect.
On May 24, 2002, Evans, having served his prison sentence, registered with the Commission as a lobbyist on behalf of five clients. On July 10, 2002, the Commission initiated a complaint against Evans based on his conviction, and on October 8, 2002, the Commission, acting under SG § 15-405(e), revoked the registrations. On Evans’s petition for judicial review, the Circuit Court for Anne Arundel County reversed the Commission’s decision on the ground that it constituted an impermissible retroactive application of § 15-405(e). The issue before us, in this appeal by the Commission, is whether the Circuit Court was correct. We shall hold that it was.
BACKGROUND
In 1979, the General Assembly enacted a fairly comprehensive Public Ethics Law for State and local government officials and employees. See 1979 Md. Laws, ch. 513. The law, subsequently codified in Maryland Code, title 15 of the State Government Article, prohibited certain conflicts of interest on the part of State officials and employees (subtitle 5), required [374]*374the annual disclosure by State public officials of certain gifts, outside employment, and financial and property interests (subtitle 6), required lobbyists, as the term was defined, to register and file certain reports (subtitle 7), created a State Ethics Commission to administer the law (subtitles 2, 3, and 4), required the local governments to adopt comparable ordinances with respect to their officials and employees (subtitle 8) , and provided for certain enforcement mechanisms (subtitle 9) .
With three exceptions added over the years, prohibiting lobbyists from accepting compensation contingent on the outcome of legislative or executive action (SG § 15-706), from engaging in certain activity relating to campaign contributions (SG § 15-707), and from making gifts to public officials or employees that the lobbyist knew the officials or employees were prohibited from accepting (§ 15-505(a)(2)), the law governing lobbyists was essentially restricted to requiring them to register with the State Ethics Commission and to file semiannual reports. Although lobbyists were, of course subject to the criminal laws against bribery, fraud, and extortion, there were, subject to the noted exceptions, no more specific ethical standards set forth in the Public Ethics Law governing what they could or could not do. Nor was there any provision authorizing the Commission to suspend or revoke a registration or to impose any meaningful administrative sanction if inappropriate conduct was discovered. If the Commission found a violation of the law, it could issue an order to cease and desist the violation and seek judicial enforcement of that order or it could issue a reprimand. A court, in an enforcement action, could fine the violator.
The lack of clear ethical standards and effective administrative enforcement came dramatically to public attention when two prominent lobbyists who practiced before the General Assembly, the second being appellee, were indicted for, and ultimately convicted in U.S. District Court of, mail fraud based on conduct directly or indirectly associated with their lobbying activities. The essence of the nine wire and mail fraud charges of which Evans was convicted was that he had in[375]*375duced a member of the House of Delegates to commence the process for introducing legislation that would be detrimental to the economic interests of certain paint manufacturers, that he then, with some embellishment, presented that prospect to those manufacturers, falsely informing them that the Mayor of Baltimore intended to support that legislation, and that, through those false representations, he induced those companies to employ him as a lobbyist for the purpose of defeating the legislation. The parties inform us that “[s]chemes of this sort, premised on phony or outright phantom legislation, are colloquially known as ‘bell ringing.’ ”
Even before the Evans indictment in December, 1999, the Legislature, in its January-April, 1999 Session, created a Study Commission on Lobbyist Ethics and charged it, among other things, with collecting information about lobbying practices, formulating a Code of Ethics for lobbyists, proposing legislation, and reporting its findings to the Governor and General Assembly. The Study Commission was to make its report by December, 1999, but, at its request, that deadline was extended to November, 2000.
In its Report, the Study Commission declined the invitation to formulate a Code of Ethics for lobbyists but recommended instead a number of statutory changes designed to prohibit certain specific practices and provide greater regulation of lobbying activities and more effective enforcement of the regulatory requirements. Among the recommendations were (1) expanding the scope of activities that would require registration, (2) prohibiting certain conduct on the part of lobbyists, (3) authorizing the State Ethics Commission to impose administrative fines and to suspend or revoke a lobbyist’s registration for certain ethical violations, and (4) strengthening available criminal sanctions by lengthening from one year to two years the statute of limitations for prosecution of criminal violations and increasing maximum fines.
A bill embodying those recommendations was introduced and enacted in the 2001 Session of the General Assembly. See 2001 Md. Laws, ch. 631. Among other things, the bill created [376]*376a new SG § 15-713 that listed 14 prohibited acts, one of which was “committing] a criminal offense arising from lobbying activity.” In SG § 15-405, dealing with the enforcement powers of the State Ethics Commission, the bill added the new suspension and revocation of registration provisions noted above. Section 15-405(e)(l) provides:
“If the Ethics Commission determines it necessary to protect the public interest and the integrity of the governmental process, the Ethics Commission may issue an order to:
(i) suspend the registration of an individual regulated lobbyist if the Ethics Commission determines that the individual regulated lobbyist:
1. has knowingly and willfully violated Subtitle 7 of this title; or
2. has been convicted of a criminal offense arising from lobbying activities; or
(ii) revoke the registration of an individual regulated lobbyist if the Ethics Commission determines that, based on acts arising from lobbying activities, the individual regulated lobbyist has been convicted of bribery, theft, or other crime involving moral turpitude.”
Section 15-405(e)(3)' provides that, if the Commission revokes a registration, the lobbyist may not engage in lobbying for compensation. Section 15-405(e)(4) requires that any complaint by the Ethics Commission based on a violation of § 15-405(e)(1) must be initiated within two years after (1) the Commission’s knowledge of the violation, or (2) the date the conviction becomes final.
Section 4 of Ch. 631 provided that the Act would take effect November 1, 2001. The Act said nothing, one way or the other, about whether any of the sanctions it included could be applied to or based on conduct that occurred before its effective date.
As noted, Evans’s conviction became final on September 29, 2000. On May 24, 2002, following his release from prison but still while on supervised release, he filed lobbying registration forms with the Ethics Commission on behalf of five clients. [377]*377There does not appear to be any provision in the law authorizing the Commission to reject a registration upon its filing, but only, upon a complaint and after a hearing, to suspend or revoke an already-filed registration pursuant to SG § 15-405(e). On July 10, 2002, the Commission filed with itself and served on Evans a Complaint against Evans, averring his conviction of a crime of moral turpitude and that the revocation of his lobbyist registrations was necessary to protect the public interest and the integrity of the governmental process. Accompanying the Complaint was a proposed interim Order for Summary Suspension that had previously been prepared by the Commission’s Staff and a notice of hearing set for August 15, 2002.1
Evans responded with a motion to dismiss the Complaint on the ground that the Commission had no jurisdiction over the actions of any lobbyist that occurred prior to the November 1, 2001, effective date of the law. The motion was not a model of clarity, but its essence was that application of SG § 15-405(e) to Evans would constitute an impermissible retroactive application of the law, and, indeed, an ex post facto law, in part because the Commission’s new enforcement authority was somehow tied to the enhanced criminal sanctions, in part because the new regulations were substantive rather than procedural in nature, and in part because application of the law to Evans would make it an impermissible “special law,” in violation of Article III, § 33 of the Maryland Constitution.2 [378]*378The “special law” argument was based on the assertion, which the Commission disputed, that Evans was the only person in the world who had been convicted of a predicate crime within two years prior to the effective date of the statute.
At a hearing on the proposed summary suspension order, the Commission Staff contended that § 15-405(e) was not being applied retroactively, but even if it was, such an application was permissible. The authority to revoke a registration, it claimed, was both procedural and remedial; it was implicit in the former statute and the Legislature undoubtedly intended for the new provisions to be available with respect to any complaint made within the two-year window from the date of final conviction. The Staff denied that § 15-405(e) constituted an ex post facto law, in that it was not punitive in nature but was for the public protection. Evans pursued his argument that the Commission was attempting to apply § 15-405(e) retroactively and that it could not do so. At the conclusion of the hearing, the Commission determined that the jurisdictional question needed additional consideration. It denied the request for summary suspension, denied the motion to dismiss with leave to resubmit it, and set the matter for further hearing on both the jurisdictional issue and, if necessary, the merits.
In advance of that hearing, the parties stipulated, among other things, that Evans had been convicted of crimes that this Court had interpreted as being crimes of moral turpitude and that the convictions arose from Evans’s lobbying activities. Evans resubmitted his motion to dismiss the complaint. The Commission understood the principal issue to be whether it could suspend or revoke the lobbying registrations based on convictions occurring before § 15-405(e) took effect.3
[379]*379On October 8, 2002, the Commission entered a Final Order in which it rejected each of Evans’s arguments and revoked his registrations. With respect to retroactivity, the Commission concluded that its use of § 15-405(e) was, in fact, a prospective, forward-looking application of the statute, in that it affected only registrations filed after November 1, 2001. It declared that a statute does not operate retroactively merely because it is applied to conduct that occurred before its enactment, unless it interferes with vested rights. When Evans was convicted of a crime of moral turpitude in September, 2000, the Commission said, he had no vested right in a lobbying registration. In part, the Commission relied on the language in § 15 — 405(e)(l)(ii) permitting revocation where the registrant “has been convicted.” The Commission regarded that language as use of the past tense which, with no qualifying language, indicated an intent that past convictions may be the basis for revocation. Thus, the Commission concluded:
“We must presume that the General Assembly’s choice of wording is not meaningless and to give full effect to the plain language of the statute, we must conclude that the legislature intended to include convictions that occurred prior to the effective date of the amendment.”
The Commission rejected the “special law” argument on the ground that there was nothing “special” about the law — it applied to anyone who had been, or will in the future be, convicted of a predicate crime within two years prior to the filing of a complaint. The limitations argument hinged on the wording of § 15-405(e)(4), requiring that the complaint be initiated within two years of (1) the Commission’s knowledge of the violation or (2) the date the conviction becomes final. Evans regarded that provision as establishing alternative periods of limitation and urged that the Commission was subject to the shorter of the two. The Commission, he said, was aware of his violations from media coverage of the events [380]*380leading to his indictment and had no more than two years from then to file its complaint. The Commission responded that, as Evans was presumed innocent of the charges until convicted by the jury, the Commission could not assume the violations until that time.
Although the Circuit Court, on judicial review of the Commission’s order, found no merit in Evans’s argument that the application of § 15-405(e) to him made that statute an impermissible “special law” or that the Commission’s complaint was barred by limitations, it concluded that revocation of the registrations based on the pre-enactment convictions constituted an impermissible retroactive application of the law. The court acknowledged that retroactive application is not inherently forbidden, provided that such application does not interfere with vested rights, but the court noted that statutes are presumed to be applied prospectively only, and “[i]n order to give retroactive effect to a statute, an intent to do so must be clearly expressed.... ” The court found no clear expression, either in the statute or its legislative history, of an intent by the General Assembly that § 15-405(e) be applied to convictions that occurred prior to November 1, 2001. The Legislature was keenly aware, it said, of Mr. Evans’s conviction, and, had it desired to permit the Commission to preclude him, or others who might have been or might yet be convicted prior to the effective date of the statute, from continuing to lobby, it could have made that intent clear.
Aggrieved, the Commission appealed, arguing that § 15-405(e) was not being applied retroactively and that, in any event, the Legislature intended for it to apply to Evans. The issue was joined as well with respect to Evans’s continued assertion that application of § 15-405(e) to his 2000 convictions would make the statute an impermissible “special law” and that the Commission’s complaint was not timely. We granted certiorari on our own initiative prior to proceedings in the Court of Special Appeals. Because we agree with the Circuit Court’s conclusion as to the retroactive application of § 15-405(e), we need not address the “special law” and limitations issues raised by Evans.
[381]*381
DISCUSSION
The issue before us is not whether, as a matter of public policy, a person who has engaged in the conduct Evans was convicted of committing should be permitted to continue to act as a compensated lobbyist. Nor, in our view, is the issue whether the Legislature had the Constitutional authority to draft the statute in such a way that would have allowed the Commission to preclude Evans from continuing to act as a compensated lobbyist based on his September, 2000 convictions. Indeed, Evans no longer contests, if he ever did, that the Legislature could have achieved that result. The only question is whether the record reveals a sufficiently clear intent by the Legislature that the statute have that effect or that it be applied in that manner.
We have articulated the rules governing the application of a statute to events that occurred prior to the effective date of the statute on a number of occasions, most recently in Allstate v. Kim, 376 Md. 276, 829 A.2d 611 (2003). We made three basic points in Kim. First, citing WSSC v. Riverdale Heights Fire Co., 308 Md. 556, 563-64, 520 A.2d 1319, 1323 (1987), we re-confirmed four basic principles:
“(1) statutes are presumed to operate prospectively unless a contrary intent appears; (2) a statute governing procedure or remedy will be applied to cases pending in court when the statute becomes effective; (3) a statute will be given retroactive effect if that is the legislative intent; but (4) even if intended to apply retroactively, a statute will not be given that effect if it would impair vested rights, deny due process, or violate the prohibition against ex post facto laws.”
The second point iterated in Kim was that, in applying those principles when an issue is raised regarding whether a statute may be given retroactive effect, we engage in a two-part analysis:
“First, we must determine whether the Legislature intended the statute to have the kind of retroactive effect that is asserted. That implicates the first and third principles. [382]*382Applying the presumption of prospectivity, a statute will be found to operate retroactively only when the Legislature ‘clearly expresses an intent that the statute apply retroactively.’ Waters v. Montgomery County, 337 Md. 15, 28, 650 A.2d 712, 718 [ (1994) ].”
“If we conclude that the Legislature did intend for the statute to have retroactive effect, we must then examine whether such effect would contravene some Constitutional right or prohibition. That implicates the second and fourth principles.”
Allstate v. Kim, 376 Md. at 289-90, 829 A.2d at 618-19.
The third point made in Kim is that the issue of intent often depends on context. We pointed out:
“The issue of intent sometimes becomes clouded when, as here, a statute can be regarded as being prospective in one sense and retroactive in another. As noted in State Comm’n on Human Rel. v. Amecom Div., 278 Md. 120, 123, 360 A.2d 1, 3-4 (1976), ‘a statute, though applied only in legal proceedings subsequent to its effective date and in that sense, at least, prospective, is, when applied so as to determine the legal significance of acts or events that occurred prior to its effective date, applied retroactively.’ Context becomes important.”
Id. at 289, 829 A.2d at 618-19.
As in Kim, § 15-405(e) was applied prospectively here in the sense that the registrations were filed and revoked after the effective date of the statute. The statute was clearly applied retroactively, however, in that the sole ground for revocation was an act — a conviction — that occurred prior to the effective date. The statute, in that sense, was applied in a way that “determine[d] the legal significance of acts or events that occurred prior to its effective date.” As we have indicated, Evans does not contest that the Legislature could validly had achieved such a result, and, indeed, the relevant case law confirms that view. See De Veau v. Braisted, 363 U.S. 144, 80 S.Ct. 1146, 4 L.Ed.2d 1109 (1960) (1953 law prohibiting a [383]*383person who had been convicted of felony from soliciting or collecting union dues on the New York waterfront could constitutionally be applied to prohibit a person who had been convicted in 1920 from collecting dues; “[b]arring convicted felons from certain employments is a familiar legislative device to insure against corruption in specified, vital areas”); Hawker v. New York, 170 U.S. 189, 18 S.Ct. 573, 42 L.Ed. 1002 (1898) (same effect, cited in De Veau); Smith v. Doe, 538 U.S. 84, 123 S.Ct. 1140, 155 L.Ed.2d 164 (2003) (citing De Veau and Hawker in support of holding that application of Alaska sex offender registration law to a person convicted prior to effective date of law did not make the law an ex post facto one); Forti v. New York State Ethics Commission, 75 N.Y.2d 596, 555 N.Y.S.2d 235, 554 N.E.2d 876 (1990).
Addressing the issue of intent in its initial brief, the Commission recognized the presumption against retroactive application, but, based on the fact that both the Study Commission created in 1999 and the Legislature itself were keenly aware of Evans’s criminal conduct, urges that “[i]t is simply impossible to believe that the General Assembly, which commissioned and relied on the Study Commission’s Final Report — a Report that stressed the need to restore public confidence in the wake of recent scandals — somehow intended to exempt the very person whose conduct, perhaps more than any other’s, spawned this legislation.” The Commission’s point is that “[a]gainst this background, if the General Assembly had intended to exempt or give ‘grandfather’ status to Evans’ conviction, it would have said so expressly.”
The problem with this assertion is that it reverses the longstanding presumption against retroactivity. In Kim, we said that, in applying that presumption, “a statute will be found to operate retroactively only when the Legislature ‘clearly expresses an intent that the statute apply retroactively. ’ ” Kim, supra, 376 Md. at 289, 829 A.2d at 618, quoting in part from Waters v. Montgomery County, supra, 337 Md. at 28, 650 A.2d at 718. (Emphasis added). In other cases, we have used even stronger language. See, for example, Williams v. Johnson, 30 Md. 500, 508 (1869) (“A statute ought not to have a retroactive [384]*384operation, unless its words are so clear, strong and imperative, that no other meaning can be annexed to them, or unless the intention of the Legislature could not be otherwise satisfied”); Dashiell v. Holland Maide Candy Shops, 171 Md. 72, 188 A.29 (1936) (confirming Williams and noting “statutes are not to be given a retroactive effect unless their words require it”); Langston v. Riffe, 359 Md. 396, 406, 754 A.2d 389, 394 (2000) (citing and confirming Dashiell).
The fact that Evans’s conduct may have helped spawn the legislative action that led to the enactment of § 15-405(e) does not mean that the Legislature intended for the Commission to be able to use conduct occurring before its effective date to revoke new registrations. It is not uncommon for a legislative body to address a problem, even a serious one, prospectively, understanding that the statute it enacts to deal with' the problem may not immediately apply to those who caused the problem. The Legislature is aware — acutely aware in light of some of our recent cases dealing with retroactive legislation— of the rules regarding that issue. The fact that the Legislature did not act affirmatively to exclude Evans or others in his situation does not suffice to overcome the presumption against retroactivity. If the Legislature wanted the statute to apply to Evans or persons in his status, it would have to have taken some affirmative action, expressly or by necessary implication, to make that clear, and there is nothing that we can find in either the statute itself or its legislative history to indicate that it did so. The fact that the Legislature was, indeed, aware of Evans’s conduct makes the omission particularly telling. Failure to expressly exclude Evans does not translate to an affirmative intent to include him.4
[385]*385In its Final Order, the Commission interpreted the language permitting suspension or revocation if the lobbyist “has been convicted” as itself indicative of an intent to permit those sanctions for convictions that occurred before the effective date of the statute, construing the language as being in the past, rather than the present, tense, and it iterates that view in its reply brief as an additional basis for finding an intent to make the statute retroactive. We find no merit in that argument. For one thing, although this case will not be decided on the basis of the precise and often arcane rules of English grammar, we do question whether “has been convicted” constitutes the past tense of the verb “convict” as the Commission posits. It seems more to be the present tense, passive voice, possibly perfect form of the verb indicating merely a current status. Whatever may be the grammatical pigeonhole, however, use of that language suggests nothing as to whether the Legislature intended the sanction to apply to conduct occurring prior to the effective date of the statute. That language is also appropriate to an entirely prospective application of the statute, allowing suspension or revocation of a registration of anyone who “has been convicted” after the statute took effect and within two years prior to the initiation of the complaint.
Finally, although, as noted, the Legislature could have drafted the statute to preclude a person who had ever been convicted of serious crime from thereafter engaging in lobbying for compensation, the Commission’s view that the statute as drafted was intended to have retroactive effect raises a much broader issue. SG § 17-113, added by the 2001 law, prohibits certain conduct on part of a lobbyist that was not previously prohibited, at least not expressly so. If the Commission’s belief that the Legislature intended the statute, as written, to have retroactive effect is correct, under § 15-405(e), the Commission could suspend a registration for any of [386]*386that conduct committed prior to the effective date of the law, at a time when it was not unlawful, and make that suspension effective for up to three years. Under § 15-405(e)(4), the Commission could take that action any time within two years after it gained knowledge of the conduct, which could be many years after the conduct occurred. Constitutionality aside, there is no basis for believing that the Legislature could have had any such intent.
The dissent agrees that, on the record before us, there is no evidence, or at least insufficient evidence, that the Legislature intended for § 15-405(e) to be applied retroactively, and it thus rejects, as do we, the Commission’s argument to the contrary. On that issue, the Court is unanimous, and, apart from whether a retroactive application would or would not impair any vested rights of Evans, that alone would preclude giving the statute a retroactive application.
The dissent skirts that problem, which we regard as the determinative factor, by expressing the belief that termination of Evans’s registration based on a conviction that occurred prior to the effective date of the statute does not constitute a retroactive application of the law. It rests that belief solely on the view that the Commission’s action did not impair any vested right of Evans or change “the legal significance of completed transactions.”
There are two problems with that proposition. First, assuming that the dissent’s view that a criminal conviction is the equivalent of a “completed transaction” is correct, we are hard-pressed to understand how § 15-405(e) which, for the first time, permitted the State Ethics Commission to revoke a lobbyist’s registration solely on the ground that the lobbyist has been convicted of certain criminal offenses, does not change the legal significance of a conviction that occurred prior to the effective date of the statute. Would the dissent also hold, under that view, that the Commission could suspend a registration for conduct, not then unlawful, that occurred prior to November 1, 2001?
[387]*387To the extent that the dissent would define retroactivity in terms of whether a statute impairs vested rights, it conflates the concept of retroactivity with Constitutionally impermissible retroactivity and, as a logical consequence, would effectively prohibit any retroactive legislation. Under that view, a statute is retroactive if it impairs vested rights, but to the extent it impairs vested rights, it cannot be given retroactive effect — a classic “Catch-22.” A statute may have retroactive effect without impairing a vested right. In St. Comm’n on Human Rel. v. Amecom Div., 278 Md. 120, 123, 360 A.2d 1, 3 (1976), we defined a retroactive statute as one “which purports to determine the legal significance of acts or events that have occurred prior to the statute’s effective date,” and we made clear that there is “no absolute prohibition against retroactive application of a statute.”
A statute may affect dealings, contracts, or statuses that existed prior to the effective date of the statute, and, to the extent that it does so, it will be regarded as retroactive. Under clear and well-established Maryland case law, there are but two brakes or caveats on permitting statutes to have that effect: first, because there is a presumption that statutes apply only prospectively, there must be clear evidence, legally sufficient to rebut that presumption, that the legislature intended for the statute to apply retroactively; and second, even if such intent is adequately established, a statute will not be permitted to so apply if such an application would impair a vested right. The second brake is a Constitutional impediment, not a definitional element. It does not make the statute retroactive — that is accomplished by rules of statutory construction in aid of establishing legislative intent — but rather precludes the statute from applying retroactively, even though that was the legislative intent. If there is sufficient evidence of the requisite legislative intent and a retroactive application would not impair vested rights, the statute may be given retroactive effect. The problem in this case is that there was insufficient evidence of legislative intent that § 15-405(e) apply with respect to convictions that occurred prior to its effective date, a deficiency recognized by the dissent.
[388]*388Because we find in this record no clear expression of an intent by the General Assembly to permit the revocation of a registration based on conduct that occurred before the effective date of the statute, it is not necessary for us to address the other issues raised by Evans.
JUDGMENT OF CIRCUIT COURT AFFIRMED, WITH COSTS.
CATHELL and HARRELL, JJ., Dissent.