Annual Unclaimed Property Reporting – Date Specifics

Annual Reporting Date Specifics:

Depending on the State, unclaimed property reports are due throughout the year, Spring, Summer, and Fall.

For States with a Fall Reporting due date, the date can be October 31 or November 1 each year. The cut off date will be June 30th of each year.

Depending on the Holder type, unclaimed property reports may be due to a State in the Spring, March 1 through May 1 every year, with a cut off date of December 31, the previous year.

Finally, depending on the Holder type and State, the unclaimed property report may be due over the Summer months such as, July 1st every year, with a cutoff date of March 1st or March 31st.

As you can see, there are numerous Reporting due dates throughout the year depending on the State, Holder type and property type being reported.

Please note, individual unclaimed property reports are due once a year, with the exception of California where they are due twice. The preliminary report is due November 1st and the final/remittance report is due the following June, between June 1st and June 15th.

For all other States, the remittance report is due at the same time the initial report is due each year.

For further clarification and compliance information regarding State unclaimed property reporting, please reach out to the professionals at PEACC.com at 410.303.5510 or email us at info@peacc.com

FREE PEACC.com NEWSLETTER

Sign up now for consulting tips and unclaimed property updates.

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

Minimize UP Exposure

How Does a Company Minimize Their Unclaimed Property Exposure & Implement Best Practices?

– Ensure you are abiding to all State reporting deadlines and compliance calendars.
– Understand and abide to the various compliance rules and regulations along with your industry requirements.
– Establish and implement unclaimed property liability accounts. Update them monthly.
– Perform all State mandated due diligence/search letter mailings.  Stay on top of rules & requirements.
– Investigate and implement any possible outsource solutions.
– File reports annually & consistently as required. Maintain copies of reports.
– Document and maintain support of what you DO NOT owe the States.
– Maintain a log of State’s offering Voluntary Disclosure Agreements (“VDA”) and all specifics.
– Conduct periodic reviews of all functions.
– Assign personnel and define rolls.

Call PEACC for Compliance
Call PEACC for Compliance 410.303.5510

UP Compliance Reviews

States Performing Formal Unclaimed Property Reviews –

There are currently only a handful of States conducting Formal Unclaimed
Property Reviews. To successfully complete one of these Reviews, the
following areas should be investigated and analyzed:

–  Any written Unclaimed Property policies & procedures.
–  Expectations about how certain Property types are handled/reported.
–  Reporting history of all entities including acquisitions & divestitures.
–  How are outstanding/uncashed checks treated on closed bank accounts?
–  Any De Minimus policies or rulings?

Call PEACC for Compliance
Call PEACC for Compliance 410.303.5510

Your Total Source for Unclaimed Property Compliance

Get in touch with us!