What Areas of a Company are Analyzed to Perform a Thorough Unclaimed Property Review or Audit?

–  Corporate structure
–  Current and previous Chart of Accounts
–  Review of Accounts that May Hold Uncashed Property
–  Review of General Leger Trial Balances
–  Any previous State unclaimed property reports.
–  Any past audit reports & results
–  Outstanding check listing of all disbursement accounts
–  Accounts Receivables aging report
–  Journal entries related to write-offs and any details
– Descriptions and any contracts related to any third-party administrators
–  Any mergers & acquisitions reports and detail

Call PEACC for Compliance
Call PEACC for Compliance 410.303.5510

TYPES OF UNCLAIMED PROPERTY AUDITS & REVIEWS

State Unclaimed Property Audit

    – done by individual State or can be done jointly with other State(s).

Reciprocal Audit

    – One State audits on behalf of other State(s)
    – Expenses and resources are shared

Private Audit Firms

     – State Contracts Out Third-Party Audit Firm
     – May Get Paid Based Upon a Percentage of What They Find

Telephone Audits & Reviews

     – State contacts Holder via phone.
     – Listen for uncertainties & inconsistencies in voice.

“Highway Audits”

     – State audit employees look for newspaper headlines, billboards and trucks while out of office for audit candidates.

For further information about the types of unclaimed property audits and how to navigate thru them,
please contact the experts at PEACC at 410.303.5510 or email us at info@peacc.com

Call PEACC for Compliance
Call PEACC for Compliance 410.303.5510

Four Phases of the Unclaimed Property Audit Process

The Four Phases of the Unclaimed Property Audit Process include:

PHASE I
  ~ Entity & property types scoping
    –  Public information review/10k
    –  Tax Return review
    –  Analysis of general ledgers & Review of all legal entities

PHASE II
~  Quantification of Any Potential Unclaimed Property
    – Bank Accounts detail (aged trial balances review)
    – Transaction level detail (aged outstanding check listings, Accounts Receivables credit write-offs, etc.)

PHASE III
~ Research Analysis, Remediation & Due Diligence Adjustments
   – Individual Property type &  Entity exposure provided to Holder.
   – Research, Remediation and due diligence results included in final findings.

PHASE IV
~ Unclaimed Property agreed upon final report and remittance sent in to State.

Call PEACC for Compliance
Call PEACC for Compliance 410.303.5510

How States are increasing enforcement and compliance with the State Unclaimed Property laws and regulations

How States are increasing enforcement and compliance with the State Unclaimed Property laws and regulations.

1) Mailing out of Compliance Reminder Notification letters.
    – Reminding Holders who do business in their State of their State reporting obligations
    – Mailing out Reminder letters of their reporting deadlines/due dates.

2)  Mailing out Self-Audit or Voluntary Disclosure Agreement (“VDA”) Invitation notices.
– Prior to initiating an unclaimed property audit, the State will mail the Holder an invitation to enter into a self audit or VDA program.

3) More States are establishing Voluntary Disclosure Programs (VDP’s) – Prior to starting an Audit, States will invite the Holder to Voluntary participate in a Self-Audit program or review.

4) Establishment of  State Voluntary Disclosure Programs/Agreements – Many States have developed Voluntary Disclosure Programs for Holders as an incentive to come into compliance with State laws without the threat of interest or penalties.

5) The Dreaded State Unclaimed Property Audit – A State may use State employees to conduct Unclaimed Property Audits on the State’s behalf.
–  Most States will use a third-party auditing firm, compensated on a agreed upon contingency fee. Although this contingency fee arrangement is currently frowned upon within the industry.

For further information regarding reports or unclaimed property compliance issues, please contact the professionals at PEACC by calling 410.303.5510 or email us at info@peacc.com

Call PEACC for Compliance
Call PEACC for Compliance 410.303.5510

Delaware Unclaimed Property (VDA)

Now that your fall unclaimed property reporting is complete, your PEACC Team of Advisors would like to announce Delaware is schedule to send out the next round of VDA invitations on November 15, 2024. The State last sent invitation letters out in February 2024.

If your organization receives a VDA (Voluntary Disclosure Agreement) invitation Letter from Delaware and fails to timely respond, you will become eligible for the dreaded, unclaimed property audit. Contact the professionals at PEACC to discuss your options, along with the process, at 410.303.5510.

https://lnkd.in/eTMSCMqp
VDA Invitation Dates – VDA Program – State of Delaware
vda.delaware.gov

State of Delaware map

Unclaimed Property Self-Audits: Two things to always keep in mind

When performing any unclaimed property self-audits or reviews, please keep two important givens in mind to alleviate troubles down the road:

1) Most companies will under estimate their true unclaimed property exposure if and when audited by the State(s).

2) A State will put the burden of proof on the Holder to prove they’re wrong. A State will presume a Holder is guilty unless they can be proven wrong.

For help in developing and implementing an annual unclaimed property reporting process or any questions regarding this process, please reach out to one of the Professionals at PEACC by calling 410.303.5510 or email us at info@peacc.com

What to Expect during your self-audit

Been given the option to perform a self-audit or review vs a state or state sponsored 3rd-party unclaimed property audit?

Here’s what to expect during your self-audit/review.

– The States allow less time to complete a self-audit/review vs a full fledged State sponsored audit to be completed.
– The States expect a thorough review of the company’s books & records for the entire lookback period. Normally 10 years plus the dormancy period.
– The State will utilize a State sponsored 3rd-party auditing firm to assist is gathering information and reviewing it.
– State report submission is normally done through a State webpage portal in a specific, State approved, format.
– If, after adequate testing and reviews are completed, Self-Audits can be completed fairly quick and without too many headaches.

For help with self-audits or any questions regarding this process, please reach out to one of the Professionals at PEACC by calling 410.303.5510 or email us at info@peacc.com

State Unclaimed Property Audit Letter

“Please forward the State your company’s written unclaimed property policies & procedures for reporting your property….”

Does the above phrase make you shiver, squirm?

Unfortunately, if your company is ever selected for the dreaded unclaimed property audit, prior to commencement, the first area of audit will be the review of the company’s unclaimed property policies and procedures.

This audit request is used to determine if the company is fulfilling their obligations of turning over their unclaimed property to the appropriate State and doing it in compliance with each State’s laws and reporting regulations. 

If the Holder has formal unclaimed property policies and procedures, great! You’re one step ahead of most companies.

You will most likely still be audited for your unclaimed property compliance, but the State or third-party auditing firm may not look as intensely at companies who do NOT have formal written policies and procedures in place.

If you do NOT have formal written policies and procedures in place within your organization or what you have can use a review or update(s), let the Professionals at PEACC assist with the development or revision of your unclaimed property policies and procedures. 

Please contact one of the professionals today at PEACC at 410.303.5510, to hear how we can develop customize unclaimed property policies & procedures or review your current policies and procedures to ensure you are compliant with your State reporting obligations.

Act now before the States come calling!

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