Unclaimed Property Compliance

18 Feb 2025
Sticky Post By Posted in D. Patrick ("Pat") Healy, Unclaimed Property Compliance, Unclaimed Property Consulting, Unclaimed Property Reporting Permalink

The Ins & Outs of State Reporting Unclaimed Property Due Dates

Sticky Post By On February 18, 2025

When it comes to submitting your unclaimed property reports, there are a myriad of State Reporting Unclaimed Property due dates including what are considered Spring States and Fall States.

Also keep in mind that, depending on the Holder type, that will also dictate when the report is due.

Most Life Insurance Companies have reports due in the Spring.

– 41 States are considered Fall Reporting, with reports due to them by October 31st/November 1st.

– 9 States have a Spring reporting deadline between  March 1st and July 1st.
        Delaware
        New York
        Connecticut
        Pennsylvania
        Florida
        Illinois
        Vermont
        Michigan
        Texas

– The above list also includes a couple of States that have reports due over the Summer/July 1st (Michigan & Texas).

– California has a preliminary report due by October 31 each year with their remittance report due in to them between the following June 1st – June 15th. The State will notify the Holder the exact final due date.

– Puerto Rico has a preliminary report due date of August 10th and the remittance report is due to the State by December 10th each year.

– Please note, the dormancy periods vary from one, three or five years amongst the States, depending on the property type. With a one year dormancy period being for Wages, Payroll or Salary. Traveler Checks have a 15 year dormancy period.

As you can see, there are an abundance of stipulations and requirements regarding unclaimed property reporting compliance. For how to navigate the reporting due date requirements, feel free to reach out to PEACC at 410.303.5510 or email us at info@peacc.com

Call PEACC for Compliance
Call PEACC for Compliance 410.303.5510
12 Feb 2025
Sticky Post By Posted in D. Patrick ("Pat") Healy, Unclaimed Property Compliance, Unclaimed Property Consulting, Unclaimed Property Reporting Permalink

How Can You Be Filing Your Unclaimed Property Reports and Still Not be Compliant?

Sticky Post By On February 12, 2025

1) By using an incorrect dormancy period or cut off date.

2) By reporting all property to the wrong State or State of Incorporation.

3) By having lapses in your reporting history.

4) By not understanding the rules of customer generated contact or interest in property.

5) By failing to report all eligible property

6) By not performing the State required Due Diligence/Search Letter function.

7) Under reporting or not reporting all property types.

8) Not using the State mandated required report formats.

For further assistance with non-compliance reporting issues, please contact a professional at PEACC at 410.303.5510 or email us at info@peacc.com

Call PEACC for Compliance
Call PEACC for Compliance 410.303.5510
31 Jan 2025
Sticky Post By Posted in D. Patrick ("Pat") Healy, Unclaimed Property Audits, Unclaimed Property Compliance, Unclaimed Property Consulting Permalink

Four Phases of the Unclaimed Property Audit Process

Sticky Post By On January 31, 2025

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

30 Jan 2025
Sticky Post By Posted in D. Patrick ("Pat") Healy, Unclaimed Property Compliance, Unclaimed Property Consulting, Unclaimed Property Reporting Permalink

Examples of Unclaimed Property in the Corporate World

Sticky Post By On January 30, 2025

– Vendor or Accounts Payable Checks
– Payroll Checks or Denied Automatic Payments/Direct Deposits
– Refunds/Rebates
– Account Receivables/Credit Balances
– Customer Overpayments
– Unapplied Cash
– Unredeemed Gift Certificates
– Dormant Back Accounts (Checking/Savings Accounts)
– Life Insurance Proceeds Due
– Uncashed Benefit Checks

Call PEACC for Compliance
Call PEACC for Compliance 410.303.5510
27 Jan 2025
Sticky Post By Posted in D. Patrick ("Pat") Healy, Unclaimed Property Audits, Unclaimed Property Compliance, Unclaimed Property Consulting Permalink

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

Sticky Post By On January 27, 2025

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
14 Jan 2025
Sticky Post By Posted in Unclaimed Property Compliance, Unclaimed Property Consulting Permalink

What Makes Up Your Yearly Unclaimed Property Process?

Sticky Post By On January 14, 2025

~ To reduce your unclaimed property liability and exposure
~ Obtain and maintain compliance with all State unclaimed property laws and regulations
~ Protect the Holder’s bottom line
~ Reunite Owner with their unclained assets; State maintains custody of property until Owner is found and reunited with lost property
~ Owners only have one centralized place to look for lost property

For help in developing and implementing an unclaimed property processes 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

Call PEACC for Compliance
Call PEACC for Compliance
09 Jan 2025
Sticky Post By Posted in D. Patrick ("Pat") Healy, Unclaimed Property Compliance, Unclaimed Property Consulting Permalink

Unclaimed Property (UP) In-house Program

Sticky Post By On January 9, 2025

Is Your Unclaimed Property In-house Program Good & Compliant?
What makes a good Unclaimed Property Program successful and good?

Is your program one of them?
It is if it:
–  Reduces any UP exposure to the various States;
–  It is compliant with all of the State reporting laws, regulations and
requirements;
–  Allows you to keep relationships with all account Owners over the
years;
–  It reunites lost/unclaimed funds with its true & rightful Owner(s);
–  It reduces the risks related to non-compliance, including:
    • Possible fines & interest penalties
    • UP audits and reviews;
–  All employees understand UP & know where to turn with questions.

12 Nov 2024
Sticky Post By Posted in D. Patrick ("Pat") Healy, Finding Unclaimed Property, Unclaimed Property Compliance, Unclaimed Property Laws Permalink

WHAT IS UNCLAIMED PROPERTY?

Sticky Post By On November 12, 2024

With all state jurisdictions having unclaimed property reporting laws & requirements and them being aggressively enforced through fines and interest penalties, you hear the question a lot, “What is unclaimed property?” Is it abandoned cars/vehicles? Abandoned land or livestock? What is it?  Well, it can be, but in this case it is unclaimed intangible property (with the exception of Safe Deposit Box contents). Considering the unclaimed property world, most unclaimed property involves the following types of intangible properties (but these are just examples and not all inclusive):

– EXAMPLES of UNCLAIMED PROPERTY –
– Unclaimed Vendor/AP checks
– Unclaimed payroll checks or direct deposits gone wrong
– Customer overpayments
– Unapplied cash accounts
– Aged Accounts Receivable credit balances
– Most Refunds due
– Unredeemed gift card/certificate balances
– Unclaimed bank accounts (checking, savings, retirement, CD’s)
– Life insurance proceeds due
– Uncashed benefit checks
– Utility deposits
– Lost shareholders or uncashed dividend checks
– Safe deposit box contents

Again, the above list are just examples of unclaimed intangible property and not meant to be all inclusive. Most companies/Holders are going to want to a look at their Accounts Payable, Payroll and Accounts Receivable areas, depending on the type of holder they are (corporation, bank or financial institution, life or non-life insurance company, etc.)

To talk further about all the unclaimed property reporting requirements and what your obligations are, and how to navigate through them, please contact the professionals at PEACC for a no obligation consultation at 410.303.5510.

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