Reviewed Your UP Policies & Procedures Recently?

Do you have internal unclaimed property policies & procedures currently in place? Is everyone at your organization on board with them and abiding to them?

If the answer to these questions are Yes, it is still advised by the States and all major Unclaimed Property Organizations (UPHLC, NAST, UPPO, etc.) that Holders should perform a review of them every 3 to 5 years. To ensure total compliance with all the State laws and regulations, yearly audits are often suggested. These State laws and requirements may change without much notice. The States put the burden of keeping track of any law changes on the Holders/Companies.

If you’re short staffed, confused or just don’t feel like performing a review of your unclaimed property Policies & Procedures, let PEACC help with it. PEACC has proven time & time again they can save you money from any non-compliance or under reporting liabilities (or over reporting) with their proven review and modifications methods.

Still questioning their review and process? Let PEACC review one or two of your recent State Unclaimed Property Reports for free. We will show you what compliance is required among the States.

Sleep better at night knowing all your yearly efforts comply with all the State compliance requirements and expectations. Don’t leave your door open to ongoing compliance issues. Be safe with PEACC’s Compliance Reviews. You could even be over reporting or underreporting. But you may never know unless PEACC conducts one of their thorough compliance reviews.

Don’t wait! There is no better time than now to have your Unclaimed Property Policies & Procedures reviewed. Get past reporting history reviewed prior to having a State contact you. This could lead to an added expense to your bottom line. As mentioned, it is recommended by the unclaimed property authorities to conduct a review of you’re past reporting history along with your Policies & Procedures every 2 to 3 years. But don’t fret, let PEACC do the work. You’ll be surprised at the results.

Please reach out to PEACC by calling 410.303.5510 or email us at info@peacc.com for further information or to commence with your FREE review. Only positive results.

Call PEACC for Compliance
Call PEACC for Compliance 410.303.5510

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

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

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