The ABC’s of State Unclaimed Property Reporting

Companies/Holders need to track all their unclaimed property, on average for either a dormancy period of 3, 5 or 7 years & resolve this unclaimed property with the Owner.

If it can’t be resolved with the Owner, it must be reported and remitted to the State of the property Owner’s last know address, based on what the outstanding item Owner’s last known address is.

However, if there is no last know address, or the item has a foreign address, it must be reported & remitted to the Holder’s State of Incorporation.

Sourcing rules for establishing where unclaimed property is to be reported:

Priority Rule #1 – Unclaimed property should be reported & remitted to the property Owner’s State of last known address.

Property Rule #2 – If the last known address is unknown or foreign, property should be reported & remitted to the Holder’s State of Incorporation or State of Principle Business.

For further information regarding where to report & remit unclaimed property please reach out to a professional at PEACC to help resolve your unclaimed property compliance issues at 410.303.5510 or email us at info@peacc.com before a State tracks you down!

Call PEACC for Compliance
Call PEACC for Compliance 410.303.5510

Unclaimed Property Reporting Steps

In order to get in and remain compliant with the State reporting requirements Holders must:

– Identify all unclaimed property on an annual basis
– Calculate dormancy periods based on the State property is due to; and depending on type of property and whether it would be reportable in 1,3, 5, 7 or 15 years
– Determine if any property may be exempt from State reporting
– Send State required Due Diligence/Search Letters out approximately 60 to 90 days prior to the State report due date
– Prepare and generate State reports in the required State format
– Update Holder records as to whether dormant property was reported/remitted to the State, paid to Owner or was an error in records

For additional information on how to track & comply with your State unclaimed property reporting obligations please contact PEACC at 410.303.5510 or email at info@peacc.com

Unclaimed Property Audits & Reviews

Who has the ability to audit Holders? Most State jurisdictions have the ability/authority to preform the dreaded Unclaimed Property Audit. Most States have their own audit staff conducting their own various State Audits. But most States still contract with third-party auditors. These third-party auditors have, in the past, conducted contingency fee Unclaimed Property Audits. Where these firms get a percentage of what they uncover from the Holder. Now, most States pay an hourly rate to perform Audits on behalf of a State. The third-party auditors under contract with most States, include the following firms:

• Kelmar Associates, LLC
• Specialty Audit Services (SAS)
• Kroll (was Versus Financial)
︎• Treasury Services Group, LLC (TSG)
• Innovative Advocates Group, LLC
• Discovery Audit Services (DAS)
• Escheatment Expertise Consulting Services (EECS)
• Faegre, Drinker, Biddle & Reath (FDBR)
• KDAC, LLC • Barnes & Thornburg
For further help in navigating the complexities of third-party unclaimed property auditors, please contact PEACC at 410.303.5510 or email us at info@peacc.com

Call PEACC for Compliance
Call PEACC for Compliance 410.303.5510

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