CHASANOW, Judge.
In 1947, Chief Justice Eather of the Supreme Court of Nevada wrote,
“Unquestionably the most difficult and perplexing problems which ever come before a court for decision are those questions which, while involving no financial consideration, have to do with those vitally important but wholly imponderable questions of human relations involving ... the care, custody, control, and welfare of a minor child.”
[400]*400Ex parte Schultz, 64 Nev. 264, 181 P.2d 585, 585 (1947). His statement is no less true today. This case vividly presents the difficult issues that may ¿rise in the private adoption of an out-of-state child. There are two facets to the problem: 1) regulation of independent adoptions by the individual states, and 2) cooperation between the states under the Interstate Compact for the Placement of Children (ICPC). Although this case may raise more questions than it answers, we believe it is appropriate to resolve the dilemma by examining the best interests of the child. We begin with a statement of the facts.
The case at bar involves an independent adoption facilitated by an attorney.1 Petitioners seek to adopt an infant boy who was born on May 28, 1989, in Virginia. They allege that, prior to the baby’s birth, they were contacted directly by the natural mother in response to an ad they placed in a Potomac newspaper. In that ad, to protect their anonymity, petitioners identified themselves by a false surname and gave a post office box as their address. Both natural parents executed consents and affidavits to be filed in the anticipated adoption proceedings. At the time of execution, either the documents did not contain the names and address of the adoptive parents or their names and address were hidden from the natural parents’ view. This was done openly with the express knowledge of the natural parents as set forth in the consents. The natural parents never knew the names or address of the adoptive parents, although petitioners aver that they met face-to-face and had several telephone conversations.
[401]*401Prior to the birth of the child, petitioners sought to invoke the ICPC by notifying the compact offices in both Maryland and Virginia of the approaching adoption. The Virginia compact office notified the attorney for petitioners that it requires that the ICPC-100A form, which initiates the process, must be completed in the natural mother’s handwriting, including the names and address of the adoptive parents. In instituting this requirement, the Virginia compact office relied on an opinion of the Virginia Attorney General, Adoption. Implementation of Interstate Compact for Placement of Children Requires Compliance with Virginia’s Placement Laws, 1984-85 Report of the Attorney General 3 (July 6, 1984) (hereinafter Va. Att’y Gen.Op.). It appears that the Maryland compact office has no such requirement. Petitioners refused to file a handwritten 100A form in Virginia, and the Virginia compact office refused to “facilitate” the adoption. In the meantime, according to petitioners, the Maryland compact office received all the necessary paperwork to process and approve the placement, but it was unable to act until Virginia fulfilled its “obligations” under the ICPC.
When the child was released from the hospital, petitioners attempted by telephone to obtain the approval of the Maryland compact office to transport the child to Maryland, but they were told that the appropriate person was out of the office. They then, without the sanction of either the Maryland or the Virginia compact office, transported the baby across the state line in violation of Maryland law and the ICPC.2 The following day, petitioners notified the Mary[402]*402land and Virginia compact offices that the placement had occurred.
Petitioners immediately filed their adoption petition with the Circuit Court for Montgomery County. After providing the judge with additional information he had requested, petitioners were notified by the court that the case was being referred for investigation to the court investigator. Before that investigation was complete, however, the judge dismissed the adoption petition. The judge found that the placement was made in violation of the ICPC and that the consents were “invalid in that the natural parents did not know the identity of the persons to whom they were giving consent and in that information of a material nature which purported to be a part of the consent was wrongfully added by other persons than the consenting parents after the signatures of the parents were obtained.” The Court of Special Appeals affirmed the judgment of the circuit court in an unreported opinion. No further effort has ever been made by the Maryland or Virginia compact offices or by any other state agency to assess the placement or to remove the child from petitioners’ care, where he remains to this day. Petitioners claim that they can no longer locate the natural parents.
This case may not be resolved by any simple application of law to facts. Society’s interest in providing a mechanism for adoption of children whose parents are unable or unwilling to care for them by persons who desire that responsibility is profound. Equally significant is the state’s obligation to regulate adoptions in order to protect the interests of the child, as well as the interests of the natural parents and the [403]*403adoptive parents, and to prevent the black market trade of infants. “[T]he black market, which has been well described as a ‘taint on civilized society,’ involves a marketeer who is simply trafficking in babies. The welfare of the child is subordinated to the profit....” G. Douthwaite, Unmarried Couples and the Law 46-47 (1979) (footnote omitted). In contrast to the black market, however, a “gray” baby market exists “where the intermediary, perhaps an attorney, a physician or a well-meaning friend of the parties, receives no fee, though perhaps the adopting couple pay the expenses of the mother’s confinement and delivery. Most states, though not actually prohibiting this form of transaction, regulate it in some way____” Id. at 47 (footnote omitted); see also B. Hartfield, The Role of the Interstate Compact on the Placement of Children in Interstate Adoption, 68 Neb.L.Rev. 292, 304 (1989) (hereinafter Hartfield). This case presents the question whether this type of interstate “gray” market adoption is governed by the regulations of the state where the child is born, the state where the adoptive parents reside, or both.
I. INTERSTATE COMPACT FOR THE PLACEMENT OF CHILDREN
“An interstate compact is basically an agreement, between two or more states, entered into for the purpose of dealing with a problem that transcends state lines.” P. Hardy, Interstate Compacts: The Ties That Bind 2 (1982); see Dutton v. Tawes, 225 Md. 484, 500, 171 A.2d 688, 696, cert. denied, 368 U.S. 345, 82 S.Ct. 385, 7 L.Ed.2d 342 (1961); Canal Co. v. Rail Road Co., 4 G. & J. 1, 128-29 (1832). A compact arises when two or more states enact essentially identical statutes which govern an area of mutual state concern and define the compact, its purposes, and policies. P. Hardy, supra, at 2; see Canal Co., 4 G. & J. at 130-34. Thus, a compact serves a dual role. It is the law of each state that enacts it, and it is an agreement between those states. In this case, there are two aspects to our treatment of the ICPC. First, we deal with that aspect that [404]*404involves an agreement between states. Second, we are concerned with that aspect of the ICPC that constitutes the law of Maryland, its violation and enforcement. C.T. Hellmuth v. Washington Metro. Area Trans., 414 F.Supp. 408, 409 (D.Md.1976).
The ICPC has been enacted in 49 states, Hartfield at 293 n. 1, including Maryland, Maryland Code (1984 & 1990 Cum.Supp.), Family Law Article, §§ 5-601 to 5-611, and Virginia, Virginia Code (1949, 1987 Repl.Vol.), Chapter 10.1, §§ 63.1-219.1, 63.1-219.2. It was “intended to facilitate interstate adoption, thereby increasing the pool of acceptable homes for children in need of placement.” Hartfield at 293. To accomplish this purpose, the ICPC “extend[s] the jurisdictional reach of a party state into the borders of another party state for the purpose of investigating a proposed placement and supervising a placement once it has been made.” Hartfield at 296. To accomplish these goals, the ICPC requires that
“[n]o sending agency shall send, bring, or cause to be sent or brought into any other party state any child ... as a preliminary to a possible adoption unless the sending agency shall comply with each and every requirement set forth in this section and with the applicable laws of the receiving state governing the placement of children therein.”
Family Law Art., § 5-604(a). “Sending agency” is defined in section 5-603(2) as “a party state, officer or employee thereof; a subdivision of a party state, or officer or employee thereof; a court of a party state; a person, corporation, association, charitable agency or other entity which sends, brings, or causes to be sent or brought any child to another party state.” (Emphasis added.) Petitioners admit that “[t]he ‘sending agency’ was the natural parents.” This conclusion follows from the inclusion of the word “person” in the statute. As recognized in Comhusker Chr. Ch. Home v. Dept. of Soc. S., 229 Neb. 837, 429 N.W.2d 359, 362 (1988): “There is nothing within the compact to indicate that, for the purposes of this statute, parents are not [405]*405persons, and in the absence of such an indication, we should not construe the language to eliminate parents from the class of persons.” Furthermore, at least one court has found that adoptive parents are not exempt from this class of “persons.” See In re Adoption of C.L.W., 467 So.2d 1106 (Fla. Ct.App.1985).
The conclusion that parents may be the “sending agency” is further buttressed by the fact that the compact provides, in section 5-609(1), that it is not applicable to “the sending or bringing of a child into a receiving state by the child’s parent, step-parent, grandparent, adult brother or sister, adult uncle or aunt, or guardian and leaving the child with any such relative or non-agency guardian in the receiving state.” (Emphasis added.) This provision would be meaningless if natural parents were not otherwise considered to be a sending agency under the compact. In this case, the natural parents and the petitioners were not acquaintances, much less related to one another. The initial link that joined them in the adoption process was a newspaper ad. Thus, they are not excused from compliance by section 5-609. Observance of the procedures of the ICPC was mandatory.
A. VIRGINIA’S RESPONSIBILITY UNDER THE ICPC
Petitioners contend that Virginia, in refusing to accept their application for interstate placement in this case, violated the ICPC. They claim that Virginia’s policy in requiring a handwritten 100A form superimposes Virginia adoption law on the ICPC which specifically requires only compliance with the terms of the ICPC and with the law of the receiving state, in this case Maryland. Md.Code, Family Law Art., § 5-604(a); Va.Code, Ch. 10.1, § 63.1-219.2, Art. 111(a); see Va.Att’y Gen.Op. at 3-4. The adoption laws of Virginia and Maryland conflict with regard to the license requirement for a child placement agency. Maryland excepts from the license requirement attorneys who “prepare pleadings necessary to accomplish the adoption of a child or ... perform any other function associated with the normal [406]*406practice of law.” Md.Code (1984), Family Law Art., § 5-507(b)(3). Virginia does not. See Va.Code (1949, 1987 Repl.Vol., 1990 Cum.Supp.), Ch. 10, § 63.1-196. Virginia claims that its policy of requiring a handwritten consent assures that the natural and adoptive parents are dealing directly and without the benefit of an unlicensed intermediary.3 The Virginia Attorney General has addressed this question:
“Your ... question is whether it would be proper, under the ICPC ..., for the [Virginia Department of Social Services] to help effect the direct placement of a Virginia child in another state when it is apparent that a party not licensed as a child-placing agency has helped the biological and/or adoptive parent(s) in locating and effecting the adoptive placement and no licensed agency is involved.
... [A] person involved in effecting the ‘placement’ of a child ... is a child-placing agency and must, therefore, meet appropriate licensure requirements. Failure of such person to comply with those requirements can result in a conviction of a misdemeanor or in the enjoining of such behavior. Because such behavior could be found to be illegal, I am of the opinion that it would be inappropriate for you to help effect the placement of a Virginia child in another state, when it is apparent that a party not licensed as a child-placing agency has assisted the biological and/or adoptive parent(s) in locating and effecting the adoptive placement.” (Citations omitted.)
Va.Att’y Gen.Op. at 4.
The ICPC does not specifically direct that the child placement laws of the sending state must be observed. It does, however, indicate that it is a stated purpose and policy [407]*407of the ICPC that “[t]he proper authorities of the state from which the placement is made may obtain the most complete information on the basis of which to evaluate a projected placement before it is made.” Md.Code, Family Law Art., § 5-602(3); Va.Code, Ch. 10.1, § 63.1-219.2, Art. 1(c) (emphasis added). This statement implies that it is the policy of the ICPC that the sending state evaluate the placement in the first instance. Otherwise, “[t]he ICPC might then be interpreted as encouraging the placement of children in violation of the placement laws of the sending state or as repealing the placement laws of the sending state in cases of interstate placement.” Hartfield at 315. The policy of requiring sending state approval is justified by the principles of comity and by the long-standing principle that the sending state stands in parens patriae to the child and is obligated to assure its welfare.4 It is not unreasonable for a state to fulfill this responsibility by insisting upon compliance with its child placement laws. As was observed in State v. Svenson: “We cannot conclude ... that the parties thereto intended by the provisions of the compact to divest themselves of the power to legislate upon the subject embraced therein....” 104 Wash.2d 533, 707 P.2d 120, 124 (1985) (quoting State v. Huse, 183 Wash. 560, 563, 49 P.2d 25, 26 (1935), in turn quoting P.J. McGowan & Sons, Inc. v. Van Winkle, 21 F.2d 76, 77 (D.Or.1927), aff'd, 277 U.S. 574, 48 S.Ct. 435, 72 L.Ed. 995 (1928)). Indeed, the Secretariat, [408]*408who is responsible for coordination of the ICPC nationwide, has opined that the ICPC requires compliance with the laws of the sending state. American Public Welfare Association, The Interstate Compact on the Placement of Children: Compact Administrators’ Manual (1982) at 3.67 (Secretariat Opinion 37 (April 7, 1977)); see also id. at 2.2-2.3 (Compact Provisions, An Interpretive Commentary).
Professor Hartfield points out that “one of the goals of the ICPC is to prevent forum shopping ... at the expense of the child.” Hartfield at 307. She suggests that adoptive parents sometimes knowingly fail to comply with the provisions of the ICPC because “one of the states might prohibit or impose greater restrictions on independent placements.” Id. at 305. In the instant case, petitioners’ action in removing the child from the state without consent obstructed Virginia’s legitimate right and obligation to oversee the welfare of its citizens, that is, the child and his natural parents. For these reasons, we do not accept petitioners’ contention that Virginia violated the ICPC by refusing to accept their application. See also People v. Thompson, 87 Misc.2d 302, 384 N.Y.S.2d 974, 978 (1976) (in construing an interstate compact regarding supervision of parolees, the court recognized that “there is nothing in the compact to compel a state to receive a parolee____ There is, therefore, no basis upon which this Court may compel that consent be given”).
B. MARYLAND’S RESPONSIBILITY UNDER THE ICPC
Apparently, “it often happens that children are placed from one compact state into another without observing compact procedures.” Matter of Adoption of Baby Boy M.G., 135 Misc.2d 252, 515 N.Y.S.2d 198, 201 (Surr.Ct. 1987); see also Hartfield at 302. Despite Virginia's failure to address this placement, once the child was present in Maryland, the Maryland compact office was capable of mitigating any potential harm to the child. While it may be the usual practice for the receiving state to initiate its [409]*409evaluation of the placement upon receipt of information from the sending state, the ICPC does not preclude Maryland from considering the placement, absent Virginia’s consent, once the child is present in this state. Although most states that subscribe to the ICPC have enacted regulations requiring involvement of the compact administrator of the sending state, Hartfield at 315, Maryland does not appear to be one of them. Petitioners represent that they filed with the Maryland compact office all of the same documentation that was filed with Virginia.5 Once the Maryland compact office was notified that the child had been placed with potential adoptive parents in Maryland, it should have initiated its investigation of the placement, regardless of whether it had received notification from Virginia. The primary purpose of the ICPC is to assure that the child being placed receives “the maximum opportunity to be placed in a suitable environment ... with persons or institutions having appropriate qualifications and facilities to provide a necessary and desirable degree and type of care.” Family Law Art., § 5-602(1). The Maryland compact office is not relieved of its responsibility to assure a child’s welfare upon its arrival in Maryland simply because the state from whence the child came has not evaluated the placement. The best interest of the child dictates that noncompliance with the ICPC in transporting a child into the state should be carefully investigated at the earliest opportunity, not ignored.
C. VIOLATION OF THE ICPC
The ICPC is a duly enacted Maryland law. Md.Code (1984 & 1990 Cum.Supp.), Family Law Art. §§ 5-601 to 5-611.[410]*4106 Petitioners violated that law by transporting this infant to Maryland without the consent of the Maryland compact office. Violation of the ICPC is punishable “in either jurisdiction in accordance with its laws”7 and by suspension or revocation of the license “or other legal authorization” which empowers the sending agency to place children. Family Law Art., § 5-605. At least one court has applied that sanction in a private adoption. In Matter of Adoption of T.M.M., 186 Mont. 460, 608 P.2d 130 (1980), the Supreme Court of Montana construed the definition of “sending agency” in the ICPC to include the adoptive parents, stating that they .“brought the child ... from Mississippi to Montana for placement with themselves in furtherance of their ultimate desire to adopt the child.” Id., 608 P.2d at 132. Holding that the mother’s consent was the “legal authorization” which empowered them to place the child with themselves for adoption, the court found,
“Thus the failure of the prospective adoptive parents to comply with the terms and procedures of the Compact constitutes full and sufficient grounds for the revocation of the ‘parent’s consent.’ ”
Id., 608 P.2d at 134. Under this analysis, which we neither accept nor reject, petitioners could be forced to deliver the child to the appropriate state agency in Maryland or Virginia; but to do so in this case would most penalize the only innocent party involved, the child.
“The resolution of cases must not provide incentives for those likely to take the law into their own hands. Thus, those who obtain custody of children unlawfully, ... must be deterred. Society may not reward, except at its peril, the lawless because the passage of time has made correction inexpedient. Yet, even then, circumstances may require that in the best interest of the child, the unlawful acts be blinked.”
[411]*411Bennett v. Jeffreys, 40 N.Y.2d 543, 550, 387 N.Y.S.2d 821, 827, 356 N.E.2d 277, 284 (1976).
The “golden rule” of adoption in Maryland is, and has always been, the best interest of the child. In re Lynn M., 312 Md. 461, 463, 540 A.2d 799, 800 (1988). The appropriate forum for final determination of the best interest of the child is the adoption proceeding in the circuit court. See id. at 466, 540 A.2d at 802. What, then, can a court do to protect a child who has been brought into Maryland without the approval of the Maryland compact office?
D. ROLE OF THE COURT
Petitioners’ failure to comply with the ICPC does not deprive Maryland of jurisdiction over the adoption. The ICPC contemplates adoption in the receiving state. While compliance with the compact is designed to assure the child’s welfare pending that adoption, the circuit court has “exclusive power to sever the legal ties between parent and child by allowing the adoption of the child by another.” Id. Approval of the compact office is necessary to assure, at the outset, that a placement is not contrary to the child’s welfare; but it is not a substitute for a judicial determination of the child’s best interest, nor is it a prerequisite to jurisdiction. The child who is the subject of this proceeding has now been present in Maryland for approximately two years, and the adoptive parents are domiciled in Montgomery County. Circuit courts have jurisdiction over adoptions in Maryland. Md.Code (1984, 1990 Cum.Supp.), Family Law Art., § l-201(a)(l). Section 6-203(e) of Md.Code (1974, 1989 Repl.Vol.), Courts & Judicial Proceedings Article, provides that “venue for a proceeding for adoption of a person who is physically within the State” (emphasis added) is in a county where the petitioner is domiciled or has resided for at least 90 days next preceding the filing of the adoption petition. Therefore, the Circuit Court for Montgomery County was an appropriate forum to consider this adoption petition.
[412]*412The fact that the ICPC had been violated in this case does not mandate dismissal; rather it indicates the need for a prompt determination of the best interest of this child. We hold that, in the instant case, the circuit court erred in dismissing this adoption petition. In the face of ICPC violation, a circuit court is not limited to granting the adoption without ICPC approval or denying the petition for adoption. It may consider other alternatives, including requiring retroactive ICPC compliance. See Hartfield at 306. Obviously, to simply grant an adoption without compact approval undermines the effectiveness of the ICPC. We therefore reject this option absent extraordinary circumstances.
With regard to denial of an adoption for failure to comply with the ICPC, we have found one case that accomplished this result. As discussed above, in Adoption of T.M.M., the Supreme Court of Montana found that the prospective adoptive parents had violated the ICPC by transferring the child from Mississippi to Montana without complying with the compact. The sanction imposed for this violation was revocation of the natural mother’s consent to the adoption. In the absence of such consent, the adoption petition was dismissed and the child returned to its natural mother. The Montana court never discussed the best interest of the child, but the child’s natural mother was a party to the proceedings. Such summary dismissal of an adoption petition on a procedural basis without consideration of the child’s welfare is not appropriate where the only parties before the court seeking custody of the child are the prospective adoptive parents. In such a case, summary dismissal would require that the child be left in limbo or placed in the custody of either the Maryland or Virginia child welfare agencies. If the child is thriving in a household where the petitioners for adoption are the only parents the child has known, it may be adverse to the child’s best interest to remove it to a social services agency solely because the adoptive parents violated the ICPC. It is not necessarily true, however, that the child is always better off with the [413]*413prospective adoptive parents rather than with a state agency. See, e.g., Denver DSS v. Dist. Court of 18th Jud. D., 742 P.2d 339 (Colo.1987) (where 2-year-old child died of “unknown and allegedly nonaccidental causes” and two others were allegedly abused during preadoptive placement).
Where a placement has been made in violation of the ICPC, there may have been no official preliminary determination that the placement “does not appear to be contrary to the interests of the child,” as required by Family Law Art., § 5-604(d). To protect the child, that determination should be made at the earliest opportunity. Requiring, whenever practicable, a retroactive compliance with the ICPC would accomplish that purpose, as well as promote, to the extent possible, the integrity of the compact.
“The predicament which the courts face is whether to allow the best interests of the child standard to control when the ICPC has been violated. If the best interests standard controls, then the adoption may be granted despite violation of the ICPC. Alternatively, if the violation of the ICPC is fatal to an otherwise desirable adoption, then a child may be deprived of the only family he has ever known, returned to a natural parent who is marginally capable of providing adequate care, or placed in foster care to await an uncertain future. Undoubtedly, it is the potentially harsh result, contrary to the best interests of the child, that has caused the compact administrators, the Secretariat, and the courts to countenance retroactive compliance with the ICPC and, where that is not possible, finalization of adoptions despite noncompliance.”
Hartfield at 319. Based on these considerations, we believe the most appropriate course, where a child has been placed in the State of Maryland in violation of the ICPC, may be to require, whenever practicable, retroactive compliance with the compact. In reaching this conclusion, we recognize “the circularity of the problem____ [B]oth retroactive com[414]*414pliance and finalization of adoptions despite ICPC violations encourage subsequent violations.” Id. At least one jurisdiction has utilized an innovative remedy—the refusal to approve the amount of attorney’s fees as requested when the ICPC has been violated. See Matter of Adoption of Calynn, M.G., 137 Misc.2d 1005, 523 N.Y.S.2d 729 (Surr.Ct. 1987). The Maryland General Assembly may wish to address the concerns raised by the limited ability to enforce the ICPC in private adoptions.
We stress that it should not be concluded from this decision that it is permissible to illegally remove a child from another state and hold it in Maryland until a sufficient time elapses so that the child’s welfare dictates adoption. The particulars of this case are unique in that neither the natural parents nor the state of Virginia have, so far, sought to exercise their claims over the child. In addition, at the time they brought the child into Maryland, the petitioners had sought to comply with the ICPC and were acting under the misconception that their act was not wrongful and that compact approval would be immediately forthcoming.
Under these circumstances, it appears to be in the best interest of this child that we remand the case to the Circuit Court for Montgomery County for a determination of whether adoption by petitioners is in order at this time. In doing so, we note the circuit court’s dilemma over the consents filed with the adoption petition. We believe, however, that it was not appropriate to simply dismiss the adoption petition where the child was in the custody of strangers and incapable of returning to his natural parents. Where the welfare of a child is at stake, the court should not, like Pontius Pilate, wash its hands of the matter. Under such circumstances, even if adoption is not in order, the court should still evaluate the best interest of the child and consider whether some action should be taken to assure the child’s needs will be met until a permanent resolution can be achieved.
[415]*415II. CONSENT TO ADOPTION
In addition to violation of the ICPC, the judge based the dismissal of this adoption petition, upon his finding that the consents were invalid “in that the natural parents did not know the identity of the persons to whom they were giving consent and in that information of a material nature which purported to be a part of the consent was wrongfully added by other persons than the consenting parents after the signatures of the parents were obtained.” The validity of such a blank consent to adoption appears to be a question of first impression in Maryland.
A. BLANK CONSENT
The reported cases dealing with the issue of validity of blank or blanket consents to adoption fall into two general categories. The first category treats the consent as merely a relinquishment of parental rights, in which case the identity of the adoptive parents is immaterial. The argument in favor of this approach is stated in Barwin v. Reidy, 62 N.M. 183, 307 P.2d 175, 181 (1957),
“Since adoption may be refused to petitioners who have the strongest endorsement of the parents, we think it follows that the office of the requirement of consent for adoption is to indicate the willingness of the parents that the natural relationship be swept away and a new one created in its stead. The giving of consent is indicative of the subjective state of mind of the parents—expressive only of the individuals and binding no one unless the court shall choose to act thereon. It is up to the court to perform the objective acts of severing the natural relationship and creating an artificial status by judicial determination. As it may or may not decree adoption in favor of persons recommended by the natural parents, it seems most unlikely the legislature intended to impose as a condition to the exercise of the court’s jurisdiction knowledge of the identity of petitioners in adoption on the part of the natural parents, because even when that circumstance exists, and possibly the further circumstance that [416]*416the natural parents have investigated the qualifications of the petitioners and given them their unqualified approval, the court may still refuse to decree adoption, the selection of a foster parent being a judicial act and the responsibility being that of the court.”
See In re Adoption of a Minor Child, 127 F.Supp. 256 (D.D.C.1954); Wolf v. Smith, 435 So.2d 749, 751 (Ala.Civ. App.1983); McKinney v. Weeks, 130 So.2d 310 (Fla.Dist.Ct. App.1961); Cohen v. Janic, 57 Ill.App.2d 309, 207 N.E.2d 89 (1965); Johnson v. Cupp, 149 Ind.App. 611, 274 N.E.2d 411, 415 (1971); Matter of Adoption of Jackson, 89 Wash.2d 945, 578 P.2d 33, 36-37 (1978). This notion is also espoused by the Uniform Adoption Act, § 7(b), 9 U.L.A. 40 (1988 & 1991 Cum.Supp.), which has been adopted in Alaska, Arkansas, Montana, North Dakota, and Ohio:
“(b) A consent which does not name or otherwise identify the adopting parent is valid if the consent ... contains a statement by the person whose consent it is that the person consenting voluntarily executed the consent irrespective of disclosure of the name or other identification of the adopting parent.”
The Comment to this section addresses the question head-on:
“Subsection (b) is designed to clarify a point which seems to be ambiguous under some law as to whether the consent must be a consent to adoption by a particular individual. The subsection authorizes a consent ‘in blank’ if the form of the consent contains a statement that a person consented voluntarily without disclosure of the name, or other identification of the adopting parent.”
In the second category of cases, the consent is viewed not as a mere relinquishment of parental rights, but as a consent to adoption by specific individuals identified therein. See Jensen ex rel. Jensen v. Creason, 264 N.W.2d 735, 738 (Iowa 1978); Matter of Adoption of X, 84 Misc.2d 770, 376 N.Y.S.2d 825, 831 (Surr.Ct.1975); Ward v. Howard, 217 N.C. 201, 7 S.E.2d 625, 628 (1940); Adoption of Ashton, 374 Pa. 185, 97 A.2d 368, 370 (1953); see also Las Vegas Sun v. [417]*417Franklin, 74 Nev. 282, 329 P.2d 867, 871-72 (1958). Under this theory, the petitioners for adoption must establish that they are, in fact, the persons to whom the natural parents consented.
There are two consents at issue in this case. The natural father’s consent to this adoption does not purport to identify the adoptive parents. It simply states, “I, ..., do hereby consent to the adoption of this child by the adopting parents chosen by [the natural mother]____” The consent of the natural mother states, “I, ..., do hereby consent to the adoption of this child by the adopting parentss [sic]: [natural parents names and address].” The mother’s consent further states,
“I specifically understood that the last name and residence of the parents adopting the baby would be unknown to me. When this document was presented to me for my signature, the last name of the adopting parents were omitted or masked from my view, as was their address. This was done with my full knowledge and consent to preserve the identity of the adopting parents and the confidentiality of the adoption proceedings.”
Maryland Code (1984, 1990 Cum.Supp.), Family Law Art., §§ 5-311 and 5-314 cover consents to adopt in Maryland. Section 5-311 states, in pertinent part,
“(a) In general.—Unless the natural parents’ rights have been terminated by a judicial proceeding, an individual may not be adopted without the consent of: (1) the natural mother; (2) the natural father____
(c) Revocation of consent.—(1) ... within 90 calendar days after the required consent to an adoption is filed under this section, or any time before a final decree of adoption is entered, whichever occurs first, the individual or agency executing the consent may revoke the consent____
(3) Except as provided in paragraph ](1) ... of this subsection, the required consent to an adoption filed [418]*418under this section may not be revoked at any time by the individual or agency executing the consent.”
Section 5-314 provides, in pertinent part,
“(a) Required notice.—The consent of a natural parent to ... an adoption ... of a child is not valid unless the consent contains an express notice of the right to revoke consent under § 5-311 ... of this subtitle____”
The statutes do not distinguish between agency and independent adoptions and do not clearly indicate whether the Legislature intended that parents who sign consents. in independent adoptions must know the identities of the adoptive parents. The issue of confidentiality in an adoption is one of great concern to adoptive parents who seek to raise their child free of interference from the biological parents. Once an adoption is enrolled, the biological parents’ rights are severed permanently and irrevocably and the adoptive parents become the true parents of the child. Protection of this relationship is significant to the child’s well-being. This fact is well-recognized in Maryland, as is the right of biological parents to remain anonymous. See, e.g., Md.Code (1982, 1990 Repl.Vol.), Health-General Art., § 4-211(e) (requiring that upon issuance of a new birth certificate after adoption the original certificate and all records relating thereto shall be placed under seal); Md.Code (1984), Family Law Art., § 5-328 (directing one placing child for adoption to make available to adoptive parents medical history of natural parents but forbidding disclosure of identity of natural parents); Md.Code (1984, 1990 Cum.Supp.), Family Law Art., §§ 5-329 and 5-329.1 (permitting disclosure of medical information but forbidding disclosure of identity of natural parents).
Generally, where an agency is involved in an adoption, confidentiality can be achieved without compromising the child’s welfare because the agency, as go-between, is the repository of identifying information for both sides. It is the responsibility of the agency to preserve that confidentiality while protecting the child’s best interests. In an independent adoption, there is no go-between. Indeed, the [419]*419reason most often cited for pursuing independent rather than agency adoption by natural parents is the ability to meet and personally approve the adoptive parents. See, e.g., S.O. v. W.S., 643 P.2d 997, 999 (Alaska 1982). In this case, the mother’s consent states, “I want to decide on with whom to place the baby.” It may appear that confidentiality is not an issue because the parties have met. In practice, however, although the parties may meet or talk by telephone, often, as in the instant case, no identifying information is exchanged. While the natural parents may meet a couple and approve of them to adopt the child, the adoptive parents’ confidentiality is preserved because the natural parents are incapable of identifying them. This may, however, cause the concern expressed by the circuit judge. If the natural parents are incapable of identifying the adoptive parents they choose, how can the court granting the adoption be assured that the parties seeking the adoption are the same persons to whom the natural parents consented? There is a risk that the use of blank consents may fuel the “black market” for infants because no safeguards assure fulfillment of the intent of the natural parent who chooses independent placement in order to personally approve the adoptive parents. Herman v. Mclver, 248 Iowa 619, 80 N.W.2d 500, 504 (1957); see also Las Vegas Sun v. Franklin, 329 P.2d at 871-72 (“[WJithout some measure of control, consents in blank in the hands of unscrupulous persons could reduce children of adoption to the commercial status of negotiable paper”).
As is clear from our discussion of the ICPC, Virginia has refused to risk the use of blank consents by requiring birth and adoptive parents to exchange identifying information. Supra note 3. This refusal to permit confidentiality in independent adoptions ensures that the placement is truly “independent” and that the parties are indisputably dealing directly with one another. It severely limits this child placement option, however, because many adoptive parents do not want to disclose their identities and risk future interference from biological parents. It also precludes ano[420]*420nymity of natural parents who desire to give up their children for adoption.
Such an approach may not be necessary to protect against the improper use of blank consents. There are other means by which petitioners for adoption may demonstrate to the court that they are in fact the persons to whom the biological parents consented. For example, the attorney for the natural parents or a neutral third person, such as a notary public, may be present during a face-to-face meeting of the parties and could later identify the adoptive parents as the persons with whom the natural parents dealt; or the consent could recite the first names and a detailed physical description of the adoptive couple. We can find no basis in the legislative history of our adoption laws to assign an intent to the Maryland Legislature that confidentiality be sacrificed in all independent adoptions. Nevertheless, because a principal reason cited for pursuing private adoption is so the natural parents may approve the adoptive parents, we are unwilling, absent a clear indication of legislative intent, to reduce a consent to an independent adoption to a mere relinquishment of parental rights. On remand, the petitioners for adoption should establish to the satisfaction of the court that they are in fact the persons to whom the natural parents directed their consents to adoption.
B. REVOCATION OF CONSENT
There is another aspect of these consents which we ■ find troubling. While the legislative intent regarding confidentiality in independent adoptions may be obscure, it is crystal clear that the General Assembly intended that all consents to adoption be revocable for a period of 90 calendar days after they are filed, or any time before a final decree of adoption is entered, whichever occurs first. Family Law Art., § 5-311; see also Haney v. Knight, 197 Md. 212, 218, 78 A.2d 643, 646 (1951). “The consent of a natural parent to ... an adoption ... of a child is not valid unless the consent contains an express notice of the right to [421]*421revoke consent under § 5-311____” Family Law Art., § 5-314. It is apparent that the Legislature was deeply concerned that a parent should have an unconditional opportunity to revoke a consent to adoption for a limited period of time. Section 5-314 requires that a parent be affirmatively notified of that right, obviously because the right is meaningless if the parent is not informed that it exists. Likewise, if a parent does not possess sufficient information to exercise the power to revoke, the right sought to be preserved by the Legislature is meaningless.
In this case, the consents contain a statement notifying the parents of their right of revocation. No instructions are included, however, which would advise them how to go about doing so. They did not know the identities of the adoptive parents. They were not represented by their own counsel. It is not clear from the record whether the parents received copies of the documents they executed. Even if they did, no information is given on the face of the consents which would enable a parent to recant. The documents do not identify the adoptive parents or their attorney, and the record does not disclose whether the natural parents knew the name of the attorney or how to contact him. Although the consent does indicate the court in which the case is to be filed, the caption is different from that in which the clerk docketed the petition. From these facts, it is questionable whether the natural parents had a meaningful opportunity to revoke. This issue should be investigated by the court on remand.
III. THE DISSENT
The dissent seems to indicate “placement” whether proper or improper is irrelevant to the adoption proceedings. See Dissenting Op. at 433, which states that “any placement of the child, if there was one within the meaning of ICPC, has already occurred. As far as the adoption proceedings are concerned, it is a moot point.” Placement should not be a “moot point”; it is illogical to suggest that a court should be unconcerned with whether a person [422]*422seeking to adopt a child secured custody of the child lawfully or unlawfully.
Maryland Code (1984), Family Law Art., § 5-304, which is part of the adoption statute, indicates placement is not a “moot point”; it provides: “This [adoption] subtitle is related to and should be read in relation to Subtitle 5 of this title.” Subtitle 5 deals specifically with placement. If we ignore ICPC placement and look only to Maryland law, then this child was unlawfully placed for adoption in violation of Md.Code (1984), Family Law Art., § 5-507(c) which is required to be read in relation to the adoption statute. Section 5-507(c) provides:
“Limitation.—A parent or grandparent may not place a child for adoption without a license unless, before the placement is made:
(1) a petition for adoption is filed in court; and
(2) the court, by order, sanctions the placement pending final action on the petition.” (Emphasis added). Pursuant to § 5-304, the placement and its legality “is
related to” and “should be read in relation to” the adoption statute. Also, the Revisor’s Note to § 5-304 cross references ICPC placements and states: “As to the requirements for bringing a child into this State preliminary to possible adoption, see also § 5-604 of this title.”
In addition, the dissent alleges that somehow the Court’s opinion “does not square with the adoption statutes and rules.” Id. at 435. The dissent reaches this conclusion arguing that by directing “retroactive, compliance with the ICPC the majority presumably intends that the circuit court requires an investigation and recommendation by the Maryland compact office. The adoption statutes, however, already provide for investigations and evaluations in connection with petitions for adoption.” Id. at 435. The dissent goes on to point out how these dual investigations would be a waste of government resources. Apparently the dissent misreads the Court’s opinion, as well as the adoption statute.
[423]*423First, this Court only directed ICPC compliance “to the extent practicable”; duplicative investigations are generally not practicable. Second, the dissent errs in citing Md.Code (1984, 1991 Cum.Supp.), Family Law Art., § 5-312 for the broad statement that the adoption statutes “already provide for investigations and evaluations in connection with petitions for adoption.” Id. at 435. That section does mandate an investigation, but is irrelevant to the case before this Court since § 5-312(a)(l) also provides that: “This section applies only to independent adoptions in which a natural parent affirmatively withholds consent by filing a notice of objection.” (Emphasis added). Clearly, it is inapplicable to the instant case or similar cases. Maryland Rule D75(b) does give the court discretion to order an investigation if the adoption proceedings are uncontested. The investigation may be conducted by “any person or agency” designated by the court. The Maryland compact office might be the appropriate agency to conduct such an investigation since the natural parents are out-of-state.
Finally, ignoring the fact that adoption proceedings are traditionally equitable in nature, the dissent repeatedly suggests that a chancellor in an adoption proceeding is limited to either granting or denying the adoption and “should not deal with matters other than whether the adoption petition should be granted under the requirements of the statutes.” Id. at 436. The Chancellor in the instant case was of a like mind, and he simply dismissed the petition and left this child in limbo. We think that the Chancellor and the dissent are in error, and that the Chancellor is not limited to either granting or denying the adoption. The Chancellor has inherent as well as express authority, when in the best interest of the child, to “deal with matters other than whether the adoption petition should be granted.” By way of example, Md.Rule D78 provides in relevant part:
“a. Duration.
The court may enter an interlocutory decree of adoption in the case of adoption of a minor, granting custody of the minor for a period not to exceed one year, retaining [424]*424jurisdiction of the proceeding, and taking such other action as it may deem in the best interests of the child.
c. Review After Year.
In a proceeding for adoption in which the last decree is an interlocutory decree, the court shall review the proceeding not later than one year from entry of the last interlocutory decree, or amendment or extension thereof, and shall enter such further decree as the best interests of the child shall require.
d. Temporary Custody.
The court may make a temporary award of custody of a minor prior to a hearing and prior to an interlocutory decree of adoption as it may deem in the best interests of the child.”
We disagree with the dissent’s conclusion that the chancellor should go no further than to merely grant or deny the petition, and we hold that the chancellor should do more and consider whether some additional action should be taken to provide for the child’s custody and welfare until a permanent resolution can be achieved.
To summarize, we remand this case to the Circuit Court for Montgomery County. We direct that petitioners should, to the extent practicable, retroactively comply with the terms of the ICPC. We further direct that the circuit court order an investigation of this placement with a view to assuring (1) that the petitioners are the same persons to whom the natural parents directed their consents and (2) that the natural parents were afforded a meaningful opportunity to revoke their consents pursuant to Maryland law. The court’s foremost consideration, however, should be a determination of whether adoption at this time would be in the best interest of this child.
JUDGMENT OP THE COURT OF SPECIAL APPEALS REVERSED AND CASE REMANDED TO THAT COURT WITH DIRECTIONS TO REVERSE THE JUDGMENT OF THE CIRCUIT COURT FOR MONTGOMERY COUNTY [425]*425AND TO REMAND THE CASE TO THE CIRCUIT COURT FOR MONTGOMERY COUNTY FOR FURTHER PROCEEDINGS NOT INCONSISTENT WITH THIS OPINION. PETITIONERS TO PAY COSTS.