Best States for Asset Protection 2026

Florida is the best state to live in for asset protection. Its constitution protects an unlimited amount of home equity from forced sale. A married couple in Florida can also own nearly everything else they hold together as tenants by the entirety: bank accounts, brokerage accounts, a business, all beyond the reach of either spouse’s separate creditors. No other state pairs an uncapped homestead with entireties ownership that broad.

We ranked all fifty states by one question: how much of one family’s property does each state’s exemption law keep from a creditor holding a large money judgment. We graded every protection against the court decisions that have tested it. Seventeen states sit lower than their statutes alone would put them, because transferring assets away from a creditor there is punished, in sixteen as a crime and in Massachusetts by jail on a civil charge.

The 2026 Rankings

The chart ranks the best states for asset protection in 2026. Each state is scored 0 to 100: the share of one family’s asset profile that its law keeps away from a judgment creditor. The two right-hand columns name the law that carries each state’s grade and the weakness that costs it most.

Rank	State	Score	Strongest protection	Weakest point
1	Florida	92.15	Unlimited homestead, entireties over everything	Almost no cash exemption for a homeowner
2	Texas	72.00	Unlimited homestead, single-member charging order	Community property, no cash exemption
3	Oklahoma	63.60	Unlimited homestead, foreclosure barred absolutely	Entireties interest can be sold on execution
4	Nevada	61.70	Best charging-order statute, tested trust law	Recorded declaration required, no entireties
5	Kansas	59.92	Unlimited homestead, conclusive IRA spendthrift	Any state tax debt forces a homestead sale
6	Wyoming	56.20	Entireties in realty and personalty, charging order	No cash exemption, $350 cap on annuity payments due
7	Virginia	55.87	Entireties in personalty, uncapped insurance	Small homestead, and only with a recorded deed
8	Delaware	55.80	Charging order and insurance both uncapped	Homestead and wildcard are bankruptcy-only
9	Rhode Island	55.30	Automatic $500,000 homestead, uncapped IRA	Defrauding creditors while insolvent is a crime
10	South Dakota	54.94	Homestead absolutely exempt, charging order	Near-empty case record, no entireties
11	Missouri	53.61	Entireties presumed for spousal deposits	Homestead of $15,000 until 2027
12	New Hampshire	52.70	Homestead tripled for 2026, uncapped IRA	Sole member can lose exclusivity, no entireties
13	Arizona	51.60	Large automatic homestead, 10 percent wage cap	Defrauding a judgment creditor is a felony
14	Iowa	51.21	Unlimited homestead, 10 percent annual wage cap	Homestead sold for traced wrongful funds
15	Massachusetts	50.00	Declared homestead of $1,000,000	Charging order has no exclusivity language
16	Washington	49.50	Homestead tracks the county median sale price	$500 ceiling on deposits and securities
17	Maryland	49.30	Entireties in realty and personalty	No homestead at all outside bankruptcy
18	Arkansas	48.42	Homestead unlimited within the acreage floor	Defrauding a creditor is a class D felony
19	Tennessee	47.65	Largest wildcard, uncapped retirement	Homestead among the weakest in the country
20	Illinois	45.90	Homestead raised for 2026, uncapped IRA	Entireties covers only homestead realty
21	Vermont	45.60	Entireties reaches a joint bank account	Homestead exposed to pre-existing claims
22	Mississippi	44.88	Uncapped retirement and life cash value	Entireties immunity never held by a state court
23	Oregon	44.08	Retirement conclusively a spendthrift trust	Charging-order statute unamended since 1993
24	North Carolina	43.68	Inherited IRAs expressly exempt	$35,000 homestead, no cash exemption
25	Alaska	43.59	Charging order covers single-member LLCs	Defrauding a creditor is a felony over $750
26	Idaho	42.80	Strongest retirement text in the country	Community property, no cash exemption
27	Montana	42.68	Homestead limit rises 4 percent every year	Recording required, foreclosure at any time
28	Connecticut	41.50	Single-member charging-order exclusivity	Entireties converted into a joint tenancy
29	Indiana	41.20	Entireties realty exempt without a limit	Charging-order statute never modernized
30	New York	40.64	Retirement conclusively spendthrift	One spouse’s interest can be levied and sold
31	Colorado	40.00	$250,000 homestead, uncapped retirement	No exclusivity language, entireties abolished
32	Hawaii	39.74	Entireties in realty and personalty	A joint account is not entireties unless titled
33	New Mexico	39.20	Uncapped insurance and annuity protection	Wildcard collapses for a defendant
34	Michigan	38.97	Foreclosure expressly prohibited	Homestead is $3,500 outside bankruptcy
35	Pennsylvania	38.80	Wages unattachable, entireties over deposits	No homestead, $300 general exemption
36	New Jersey	37.40	Uncapped retirement, no forced partition	No homestead, $1,000 personal property
37	Utah	36.80	Inherited retirement funds expressly exempt	No wildcard, entireties converted by statute
38	California	36.32	Homestead up to $600,000 by county median	IRA protected only as needed for support
39	North Dakota	35.60	Charging order names single-member LLCs	Retirement capped at $400,000 in total
40	Maine	35.26	Wages beyond trustee process, charging order	Small homestead with a tort carve-out
41	South Carolina	34.80	Personal-service earnings not garnishable	Cash exemption lost by claiming the homestead
42	Wisconsin	34.00	Homestead doubled, 80 percent of wages exempt	Owner’s own plan limited to support
43	Ohio	33.60	Foreclosure barred under any law	Defrauding a creditor is a felony over $1,000
44	Georgia	33.40	Undistributed IRA balances, uncapped insurance	Charging order expressly non-exclusive
45	Minnesota	33.23	Homestead above the profile’s equity	IRA capped by statute, then a support test
46	Louisiana	32.88	Insurance reaches the insured’s own estate	Community reachable for a separate debt
47	Alabama	32.34	Retirement unassignable, no foreclosure right	No entireties protection, $15,000 homestead
48	West Virginia	27.44	Uncapped IRA, 20 percent wage ceiling	$5,000 homestead outside bankruptcy
49	Kentucky	23.62	Uncapped IRA where the plan conforms	$5,000 homestead defeated by earlier debts
50	Nebraska	20.96	85 percent of a head of family’s earnings	Retirement exempt only as needed for support

Updated August 2026. Download the 2026 rankings report (PDF).

How We Ranked All Fifty States

We scored every state against the same case. The family owns a home with $500,000 of equity, retirement accounts holding another $500,000, a $100,000 investment and savings balance, a stake in the family business, life insurance, and two paychecks. The debtor is a married professional sued on a business or professional liability claim, ending in a large money judgment collected outside bankruptcy.

We weighted the components by where a family’s wealth sits: home equity carries 30 of the 100 points, retirement accounts 25, property the couple holds jointly 20, the business interest 10, life insurance and annuities 10, and wages 5. A state’s base score is the share of the weighted profile its exemption laws keep from the judgment.

Individually titled cash and brokerage accounts carry no weight, because no state protects them beyond token amounts. We verified all fifty: the largest exemption a homeowner can claim for plain cash is $10,000, in Nevada and Tennessee, and twenty-two states protect nothing at all. Protection for cash comes from titling it correctly or converting it into an exempt asset.

We graded tenancy by the entirety as its own protection, separate from the homestead, because the estate differs state to state. Some states extend it to everything a married couple owns together. Others confine it to real estate, and a few use the name while letting a creditor levy on one spouse’s interest anyway. Where it exists, a divorce, the death of one spouse, or a judgment against both spouses defeats it everywhere.

A state’s court record then discounts its base score, up to one quarter. Florida carries the smallest discount, because creditors have tested each of its heavy protections in its appellate courts and the debtor has generally won. Most states sit near the default, because their exemption statutes have rarely been tested against a creditor at the appellate level.

A state with a domestic asset protection trust statute earned a bonus of up to five points, and only for its own residents. Nevada earned the full five; no other state earned more than three. States whose criminal law reaches a debtor’s transfer took a deduction, priced by the grade of the offense.

We read every statute we graded in its current text and archived more than 560 of them, section by section, with their effective dates. Where a grade turned on a court decision, we read the decision, and the load-bearing opinions are linked from this page as PDFs. The grades are our judgment as asset protection attorneys, applied the same way to all fifty states, and the downloadable report names the statute or the case behind every grade. Everything is current as of August 2026, and we re-verify the full table annually.

Why Florida Ranks First

Florida’s homestead protection has no dollar limit. It sits in the state constitution, where the Legislature cannot cut it back. The exemption is automatic and covers half an acre inside a municipality or 160 acres outside one. Only three kinds of debt can force a sale: taxes and assessments on the property, obligations for its purchase or improvement, and labor performed on it.

Tenancy by the entirety does the same work for what the couple owns together. Florida presumes that jointly held spousal property is entireties property a creditor of one spouse alone cannot reach (Beal Bank, SSB v. Almand & Associates, 780 So. 2d 45 (Fla. 2001)). A statute reaches further for bank accounts, presuming entireties ownership of a married couple’s joint account unless a writing specifies otherwise (Fla. Stat. § 655.79(1)).

The presumption covers real estate and personal property alike, and in Loumpos v. Bank One, 423 So. 3d 856 (Fla. 2025), the Florida Supreme Court held it reaches a joint spousal account even where one spouse opened the account originally. The protection has two limits. A creditor holding a judgment against both spouses can reach entireties property, and a federal tax lien attaches to one spouse’s interest (United States v. Craft, 535 U.S. 274 (2002)).

The rest of the profile is covered by statute. Retirement accounts are exempt with no dollar cap, and the statute names inherited IRAs (Fla. Stat. § 222.21). Life insurance cash value and annuity proceeds are exempt with no cap (§ 222.14). A head of family’s earnings are exempt with no dollar ceiling (§ 222.11), though a debtor who signs a written waiver exposes the portion above $750 a week. The garnishment stops at 25 percent of disposable earnings. Head of family status requires more than half the support of a child or other dependent.

A Florida homeowner has almost no exemption for plain cash. The constitution allows $1,000 of personal property, and the $4,000 wildcard is available only to a debtor who does not claim the homestead. A single-member LLC can be foreclosed under § 605.0503(4); charging-order exclusivity protects multi-member companies, so the standing fix is a second member. And an IRA can forfeit its exemption when it is not run according to its own governing documents, which is how the debtor in Yerian v. Webber, 927 F.3d 1223 (11th Cir. 2019), lost an uncapped exemption.

The Rest of the Top Ten

The nine states behind Florida each protect the home or the retirement accounts outright, and each leaves at least one major asset class exposed.

2. Texas

Texas protects a home without any value cap, on ten urban acres or two hundred rural acres for a family, automatically. Retirement accounts are exempt with no dollar limit, and the statute names inherited IRAs and inherited Roth accounts (Tex. Prop. Code § 42.0021).

The charging order is the exclusive remedy for single-member and multi-member companies alike, and a 2023 amendment bars foreclosure of the charging lien “under this code or any other law” (Tex. Bus. Orgs. Code § 101.112). A Houston appellate court declined to import the single-member exceptions other states created (Pajooh v. Royal West Investments LLC, 518 S.W.3d 557 (Tex. App. 2017)).

The exposure is the marriage and the cash. Texas is a community-property state with no tenancy by the entirety. Its family code subjects all community property, including assets only the non-debtor spouse manages, to either spouse’s tort liability (Tex. Fam. Code § 3.202(d)). The $100,000 family personal-property exemption covers a closed list that includes no cash, no bank deposits, and no securities. Wages cannot be garnished for an ordinary judgment (Tex. Civ. Prac. & Rem. Code § 63.004), but that shield ends the day the paycheck is deposited.

3. Oklahoma

Oklahoma’s homestead is unlimited in value on 160 rural acres or one urban acre. One cliff sits inside it: when business use takes more than a quarter of the home’s floor space, the exemption collapses to $5,000. Retirement accounts are exempt with no cap, and Oklahoma protects distributions out of them as well, which most states do not (Okla. Stat. tit. 31, § 1(A)(20)).

The charging-order statute covers single-member companies and says a charged interest “shall in no event” be converted to a membership interest through foreclosure (Okla. Stat. tit. 18, § 2034). Life insurance and annuities are exempt with no cap and no beneficiary conditions.

Two findings pull Oklahoma down. Its entireties statute creates the estate in real and personal property, then permits “execution, levy and sale” of one spouse’s interest (Okla. Stat. tit. 60, § 74). That is the opposite of the Florida rule, and we found no Oklahoma decision protecting entireties property from one spouse’s creditor. And in Burrows v. Burrows, 886 P.2d 984 (Okla. 1994), the Oklahoma Supreme Court enforced an exception to the homestead found nowhere in its text, calling the exemption “a shield, not a sword.”

4. Nevada

Nevada writes the strongest charging-order statute in the country: the order is the exclusive remedy whether the company has one member or many, foreclosure is barred, and “no other remedy may be ordered by a court” (Nev. Rev. Stat. § 86.401). Retirement accounts are exempt to $1,000,000, inherited accounts included. A separate exemption protects $10,000 on deposit, and no state protects more plain cash; only Tennessee’s wildcard matches it.

The homestead protects $605,000 of equity, but only after the owner records a written declaration. An unrecorded Nevada homestead protects nothing.

Nevada is also the one state whose supreme court has enforced a domestic asset protection trust statute against a live creditor claim. In Klabacka v. Nelson, 133 Nev. 164, 394 P.3d 940 (2017), the court held that a Nevada self-settled trust cannot be ordered to pay the settlor’s personal obligations. The same statute lists no exception creditors at all, not even support claimants.

The decision has limits: in the case itself, the spouse’s community-property share was never shielded, and the support awards remained enforceable against the settlor personally. Nevada is a community-property state with no tenancy by the entirety.

5. Kansas

Kansas protects the home without a value limit, on 160 farm acres or one acre in town. Its IRA exemption comes with a conclusive presumption that the account is a spendthrift trust (K.S.A. 60-2308). The charging order is the exclusive remedy whether the company has one member or more, with foreclosure barred (K.S.A. 17-76,113).

The crack is the tax collector. In Bank of Kansas v. Davison, 253 Kan. 780, 861 P.2d 806 (1993), the Kansas Supreme Court held that any Kansas state tax debt, sales tax included, forces the sale of the unlimited homestead. No fraud or wrongdoing is required. Kansas also has no entireties protection, no cash exemption, and no annuity exemption that we could locate, and a new life insurance policy is unprotected for its first year.

6. Wyoming

Wyoming is the most lopsided state in the top ten. Its retirement exemption has no cap and reaches inherited accounts by the statute’s own text (Wyo. Stat. § 1-20-110). The charging-order statute is exclusive for “any judgment debtor who may be the sole member” and bars foreclosure (Wyo. Stat. § 17-29-503(g)).

Wyoming also recognizes tenancy by the entirety in both real and personal property. In Lurie v. Blackwell, 2002 WY 110, 51 P.3d 846, the Wyoming Supreme Court quashed a writ of execution against entireties property where the judgment ran against the husband alone. Its trust statute gives creditors two years, cut to 120 days once statutory notice goes out unless the creditor proves a claim that predates the transfer, and we found no decision testing it.

The rest of the profile is exposed. Wyoming exempts no cash, deposits, or securities in any amount. The annuity exemption caps benefits already due at $350 a month, on the one federal decision construing it. A policy’s cash value stays with the owner unless he changes the beneficiary for his own advantage, on an unpublished Tenth Circuit prediction no Wyoming court has tested. The homestead is $100,000 per owner, $200,000 for a couple.

Two traps ride the entireties protection. A Wyoming account must say entireties in the account title, because the marital presumption covers real-estate deeds only. And the protection stops at the state line. The same couple’s property in Lurie was reached in Montana (Lurie v. Sheriff of Gallatin County, 2000 MT 103).

7. Virginia

Virginia protects a married couple through the entireties estate rather than through exemptions. Tenancy by the entirety covers personal property by statute (Va. Code § 55.1-136). The Supreme Court of Virginia has called entireties property “completely immune from the claims of creditors against either husband or wife alone” (Vasilion v. Vasilion, 192 Va. 735, 66 S.E.2d 599 (1951)).

The same statute lets a couple move entireties property into a joint trust without losing the immunity, a clause almost no other state has. Insurance is the other strength. The cash value of a life policy and annuity benefits are protected against the owner’s own creditors with no cap (Va. Code § 38.2-3122).

Virginia’s weaknesses are the homestead and the titling formalities. The homestead is $50,000 (Va. Code § 34-4) and exists only when the debtor records a homestead deed in time; an unrecorded claim protects nothing (Va. Code § 34-6). Entireties ownership is not the default either. The deed or account must designate it, or the spouses take as ordinary co-owners.

The charging order is the exclusive remedy, and the Virginia Court of Appeals held in April 2026 that a court may not foreclose on a charged interest (Vaughn v. Farhat, No. 0162-25-2 (Va. Ct. App. Apr. 21, 2026)). Virginia’s self-settled trust statute leaves creditors a five-year window, against two years in Nevada and Wyoming.

8. Delaware

Delaware pairs top-tier entity statutes with no homestead at all. The charging order is the exclusive remedy for companies of any size, and the statute separately bars creditors from reaching the company’s own property, a protection most states omit (6 Del. C. § 18-703). Retirement accounts are exempt from execution with no cap, inherited accounts included. Delaware also exempts 85 percent of wages, and its insurance and annuity protections are uncapped.

Delaware’s $200,000 homestead exists only inside bankruptcy; the subsection’s own opening words are “In any federal bankruptcy or state insolvency proceeding.” A plain judgment creditor faces no Delaware homestead and a $500 personal-property allowance.

Entireties protection rests on old lower-court decisions. A spousal joint account was treated as entireties property in Hoyle v. Hoyle, 66 A.2d 130 (Del. Ch. 1949). In William M. Young Co. v. Tri-Mar Associates, 362 A.2d 214 (Del. Super. 1976), a car titled to husband and wife was presumed entireties property. The court ordered the levy on it set aside unless the creditor rebutted that presumption by a deadline. The Delaware Supreme Court has never decided whether entireties reaches a bank account.

Delaware’s trust statute dates from 1997. The one Delaware decision to involve it ended on a filing deadline, without reaching whether the trust would hold (TrustCo Bank v. Mathews (Del. Ch. 2015)).

9. Rhode Island

Rhode Island protects the two heaviest assets and almost nothing else. The homestead exemption is $500,000 and automatic, with no declaration or deed language required (R.I. Gen. Laws § 9-26-4.1), and IRAs are exempt with no cap, distributions included. The homestead has two carve-outs. It gives way to a federally insured lender collecting its own loan, and it does not cover debts contracted before the home was acquired.

Everything else is exposed. The charging-order statute is a bare three sentences with no exclusivity language. Life insurance is protected only for a beneficiary other than the insured, and we found no Rhode Island exemption for a debtor’s own cash value or annuity.

Entireties protection covers real estate only, and even there the creditor can wait the couple out. A forced sale is barred during the joint lives (Bloomfield v. Brown, 25 A.2d 354 (R.I. 1942); In re Gibbons, 459 A.2d 938 (R.I. 1983)). But the creditor can attach one spouse’s interest, and the attachment can be enforced later where the debtor spouse outlives the other (Cull v. Vadnais, 406 A.2d 1241 (R.I. 1979)). Rhode Island’s trust statute excepts any claimant whose injury predates the transfer, which is exactly the creditor this ranking assumes.

10. South Dakota

South Dakota’s homestead is “absolutely exempt” with no value cap while the owner is under seventy; at seventy, a $170,000 ceiling replaces the unlimited protection (S.D. Codified Laws § 43-45-3). Retirement accounts are protected to $1,000,000. The charging order is exclusive for single-member companies. A $7,000 head-of-family wildcard expressly reaches money in the bank.

Insurance is the exposure. South Dakota protects $20,000 of death proceeds and caps the annuity exemption at $250 per month, a figure set in 1966. No South Dakota statute protects a policy’s cash surrender value.

South Dakota’s asset protection reputation rests on its trust industry. Its exemption statutes are almost untested: we could not find a South Dakota appellate decision testing the homestead, the retirement exemption, or the charging order against a creditor on the merits. The same is true of its self-settled trust statute, which no creditor claim has tested in a South Dakota court.

The Five Weakest States for a Judgment Debtor

Nebraska, Kentucky, West Virginia, Alabama and Louisiana finish last. Nebraska protects a retirement account under no fixed rule at all, which is the most consequential defect of the fifty. Minnesota, one place above this group, does the same. Both make the exemption turn on what a court finds reasonably necessary for the debtor’s support, and in Minnesota a real debtor’s $51,900 IRA was found not reasonably necessary and stayed garnishable.

Minnesota holds one of the largest homesteads in the country and still finishes forty-fifth. It caps the exemption for IRAs and other non-ERISA accounts at $84,000 combined, and anything above the cap is exempt only under the support test. Minnesota abolished tenancy by the entirety in 1890, has no wildcard and no bank-account exemption outside bankruptcy, and its charging-order statute permits foreclosure on its face. A large homestead protects one asset, and Minnesota does very little for the rest.

Kentucky and West Virginia both reserve their familiar homestead figures for bankruptcy filers. A West Virginia judgment debtor gets $5,000, not the $35,000 most charts print, and the state’s own supreme court called the constitutional floor miserly. Kentucky’s $5,000 disappears where the debt predates the purchase, and its general exemption exists only inside a federal bankruptcy proceeding. Neither state protects the house in any practical sense, and the house is the heaviest thing the ranking measures.

Alabama protects the retirement account well and the house barely. Its homestead is $15,000 against this profile’s $500,000 of equity, and joint owners including spouses hold as tenants in common, so a married couple gets no entireties protection either. Alabama, Kentucky and West Virginia also make it a crime for a debtor to convey property with intent to defraud a judgment creditor.

Louisiana does one thing better than any other state. Life insurance and annuity protection reaches cash surrender value and runs even to the insured’s own estate. What sinks Louisiana is community property. A separate obligation of one spouse may be satisfied from the whole community, so joint titling enlarges the creditor’s pool instead of shrinking it.

States Where Defrauding Creditors Is a Crime

Seventeen states punish a fraudulent transfer, sixteen as a crime and Massachusetts by jail on a civil charge, and eight more make it a crime once an insolvency proceeding is pending or about to begin. Everywhere else, Florida included, the remedy is civil: the court unwinds the transfer.

What the Ranking Does Not Measure

We left taxes and the cost of living out of the scores. A state income tax decides where a family keeps more of its income; it does not change what a judgment creditor can take.

We also did not compare exception creditors, because the differences among states are small. Child support and federal tax claims reach exempt assets in nearly every state. A federal tax lien attaches even to one spouse’s interest in entireties property under United States v. Craft.

The federal layer is the same everywhere. An employer 401(k) covered by ERISA is protected the same in all fifty states, which is why the retirement grades turn on IRAs. And in bankruptcy, a trustee has ten years to reach assets a debtor moved into a self-settled trust, wherever the trust was created (11 U.S.C. § 548(e)).

The ranking gives no state credit for attracting out-of-state trust business. About twenty states have domestic asset protection trust statutes, and each DAPT state earned its bonus only for its own residents, because the statutes have not protected outsiders.

In In re Huber, 493 B.R. 798 (Bankr. W.D. Wash. 2013), a court voided an Alaska trust settled by a Washington resident, applying Washington law. In Toni 1 Trust v. Wacker, 413 P.3d 1199 (Alaska 2018), Alaska’s own supreme court held that its exclusive-jurisdiction statute cannot stop a fraudulent transfer claim in another state’s courts. For a person who does not live in a domestic asset protection trust state, an out-of-state trust of this kind is not a reliable protection.

The difference between a DAPT and a Cook Islands trust is jurisdiction. A U.S. court’s order binds an American trustee and does not bind a trustee in the Cook Islands. With an offshore trust, legal ownership sits with a foreign trustee outside the reach of any state court.

No U.S. judgment is enforceable in the Cook Islands of its own force; the creditor must start over under Cook Islands law. We rank the best asset protection jurisdictions offshore on different questions: the trustee market, whether the country recognizes foreign judgments, and the litigation record.

Can Moving to Florida Protect Your Assets?

Yes. Florida’s exemptions protect people who make Florida their home, and they apply against a creditor whose claim predates the move. Neither the homestead nor the entireties presumption draws a line between a lifelong resident and a new one.

Buying a Florida homestead with money a creditor could otherwise reach, even with intent to hinder, delay, or defraud that creditor, falls outside the constitution’s three exceptions. The Florida Supreme Court so held in Havoco of America, Ltd. v. Hill, 790 So. 2d 1018 (Fla. 2001). Among the states with no dollar cap on the homestead, Florida is the only one whose supreme court has confirmed that protection in the modern era.

Through an equitable lien, courts still reach a homestead bought with money traceable to actual fraud or theft. Inside a bankruptcy case the protection is cut back by 11 U.S.C. §§ 522(o) and 522(p).

The statutory exemptions are a different case. A late conversion of cash into an annuity or a life insurance policy can be unwound under Florida’s fraudulent-conversion statutes (In re Levine, 134 F.3d 1046 (11th Cir. 1998)). That attack reaches the statutory exemptions; it does not reach the constitutional homestead.

Entireties protection is set at account opening. Florida treats a new joint spousal account as entireties property by default, so the clean path for a new resident is opening new joint accounts rather than retitling old ones. Loumpos gives a couple a defense for an account converted years earlier; it is not a reason to plan one that way.