title: US-MD — Correspondent Banking, Settlement & Access (W12) | World Payments Monitor canonical: https://payments.gi/jurisdictions/united-states-maryland/w12/ ### W12 Correspondent Banking, Settlement & Access Uncertain re-verified 2026-10-18 · changed 2026-07-05 Maryland has no distinct state-level correspondent-banking or settlement-access statute; correspondent relationships and settlement-system membership for Maryland-chartered and Maryland-domiciled institutions are governed by the federal framework (Federal Reserve, OCC, FDIC) rather than state law, with the state's role limited to chartering and supervising depository/trust institutions that then access federal settlement rails. Standing sub-brief · as of 5 July 2026 135 words · last cycle 2026-07-05 #### Correspondent Banking, Settlement & Access Maryland has no distinct correspondent-banking statute; settlement access instead flows through OFR's Depository Supervision Unit, which charters and supervises all Maryland-chartered banks, credit unions, and trust companies as the gateway to federal Fed/OCC/FDIC settlement-system access. This module's bank-versus-nonbank asymmetry is the analytical spine here: chartered depositories hold direct settlement access that non-bank licensees do not. The 2026 amendments to the nondepository trust-company charter, carried in HB1355, authorize the Commissioner to reduce capital-stock requirements in certain circumstances, a provision relevant to reserve-custody and settlement arrangements for a prospective stablecoin issuer. #### Outlook This module's trajectory is stable in structure but consequential in direction: the new trust-company capital flexibility bridges licensing, stablecoin, and correspondent-access questions, and it is worth tracking how OFR calibrates reserve-custody expectations as the Stablecoin Act's 2027 in-force date approaches. no periodic updates on record for this sub-brief ** Sources and findings (3 unique sources · R-3/R-4)** 1. [W12-E1] T1 Derived: Confirmed [in_force https://labor.maryland.gov/finance/banks/](https://labor.maryland.gov/finance/banks/) re-verified 2026-07-05 OFR's Depository Supervision Unit regulates, supervises, and examines all Maryland-chartered banks, credit unions, and trust companies, which is the state's mechanism for granting the charter status that in turn enables federal settlement-system and correspondent-account access. 2. [W12-E2] T1 Derived: Confirmed [in_force https://mgaleg.maryland.gov/2026RS/bills/hb/hb1355f.pdf](https://mgaleg.maryland.gov/2026RS/bills/hb/hb1355f.pdf) re-verified 2026-07-05 2026 amendments authorize the Commissioner to reduce capital stock requirements of trust companies under certain circumstances and require disclosures in nondepository trust company articles of incorporation, provisions directly relevant to how a state-chartered stablecoin issuer would access reserve custody and settlement arrangements. 3. [W12-E3] T4 Derived: Uncertain [in_force https://builtin.com/companies/location/baltimore/type/fintech-companies](https://builtin.com/companies/location/baltimore/type/fintech-companies) re-verified 2026-07-05 M&T Bank, headquartered with major Maryland operations, provides banking, investment, insurance and mortgage financial services across a nine-jurisdiction footprint, implying reliance on federal correspondent and settlement infrastructure rather than a distinct Maryland-specific access regime.