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Starting October 1, a Maryland Bank Can Sit on Your Own Withdrawal for 25 Business Days

Maryland's Vulnerable Adult Banking Protection Act takes effect October 1, 2026. If you are 65 or older, your bank can delay a disbursement it suspects is exploitation, hold it up to 25 business days, and claim immunity for doing it. Here is the one thing to set up before then.

An older couple sitting on a sofa at home reviewing a paper statement with a smartphone and cash on the coffee table

If you are 65 or older and you bank in Maryland, a rule changes under you on October 1. Your bank gets to decide that a withdrawal you asked for looks like someone is taking you for a ride, and hold it. Up to 25 business days. About five calendar weeks.

You did not do anything to trigger this. You had a birthday.

The Vulnerable Adult Banking Protection Act, Chapter 511 of this year, lets a bank or credit union delay a disbursement when it reasonably believes the money is headed into financial exploitation. To use the power, it has to do two things: give you written notice of the reason within four business days, and report the suspicion to Adult Protective Services, a law enforcement agency, or the State’s Attorney.

Then the clock. The hold expires when the institution clears you, or at 15 business days, whichever lands first. APS or police can push it to 25 business days. And per the state’s own fiscal note, with no request and no court order, the bank may extend it to 25 business days anyway.

Here is the sentence to read twice. A fiduciary institution acting in good faith and exercising reasonable care has immunity from administrative and civil liability, for the notices and for the delay or denial. Your money, their judgment.

The problem it targets is not made up. FinCEN reviewed a year of Bank Secrecy Act filings ending June 15, 2023 and counted 155,415 reports of elder financial exploitation tied to roughly $27 billion in suspicious activity. About 80% of that was strangers running scams. The remaining 20% was theft by someone the victim knew, which is exactly why the law says the bank must not send the notice to a party it suspects. Sometimes the person who would read your mail is the problem.

So this is not dumb. It is a real fix with a real cost, and the cost is that a wire you needed on Friday can now be a wire you get in October. Whether that trade is worth it is your call. What is not your call is whether the power exists. On October 1, it does.

Three things this month. The first takes ten minutes.

Name a trusted contact at every bank and credit union you use. The statute builds the concept in: a family member, someone authorized to transact on the account, someone legally responsible for your finances, or a person you designate. A bank with a name and a phone number on file resolves a suspicion in a day. A bank with a blank field files a report and waits. If your institution has no trusted contact field, send the name in writing through secure message and keep the confirmation.

Second, call ahead on anything large or unusual. Buying a car with cash, paying a contractor, moving money to a new account, helping a grandchild. Tell the branch before the transaction, not after. You are giving them the story so they do not have to invent one.

Third, stop keeping the entire cushion in one place. A hold at one institution should not be able to strand your rent. Splitting an emergency fund across two banks costs you nothing when both pay a competitive rate. Compare what you are actually earning against the current top payers in our savings hub and the best savings accounts list, and run the second account through the savings calculator so the split is not costing you yield.

If you are a Maryland adult child watching a parent’s accounts: this law is now your tool. Ask to be named the trusted contact while your parent is the one making the call.

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Frequently asked questions

Who does the Maryland law actually cover?

An 'eligible adult' means someone who lives in Maryland and is either at least 65 years old, or is a 'vulnerable adult,' defined as an adult who lacks the physical or mental capacity to provide for their own daily needs. It applies to accounts you own and accounts where you are the beneficiary. There is no separate test for the 65-and-over group. Turning 65 is the qualification.

How long can the bank actually hold the money?

The delay ends when the institution decides the disbursement is not exploitation, or 15 business days after the request, whichever comes first. Adult Protective Services, a law enforcement agency, or a State's Attorney can ask to extend it to 25 business days from the original request. The fiscal note also says that even with no request and no court order, the institution may extend the delay to 25 business days on its own. That is roughly five calendar weeks.

Do I get told why my money is being held?

Yes, in most cases. Within four business days of the disbursement request, the institution has to give written notice of the reason to all parties authorized to transact on the account. The exception is the point of the law: it may not send that notice to a party it reasonably believes is the one doing the exploiting. It also has to notify local Adult Protective Services, a law enforcement agency, or the State's Attorney.

Can I sue the bank if it gets this wrong?

Not easily. A fiduciary institution acting in good faith and exercising reasonable care has immunity from administrative and civil liability, both for the notices it sends and for the delay or denial itself. Read that clause before you assume a wrongly held payment has a remedy attached.

Which institutions does this cover?

Fiduciary institution is already defined in Maryland law and it is broad: national banking associations, state banking institutions, out-of-state banks with a branch in Maryland, state or federally chartered credit unions, savings and loan associations, and other organizations supervised by the Commissioner of Financial Regulation. Maryland already imposed a version of this on broker-dealers and investment advisers back in 2017.

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