PEACC.com New To State Unclaimed Property Reporting Requirements?

Who Is Required To Report Unclaimed Property?

1) Corporations –
Retail
Manufacturing
Service/Hospitality Industry
Others (Utilities, Gov’t Jurisdictions,
Colleges/Universities, Hospitals, etc.)

2) Banks & Financial Institutions

3) Insurance –
Life Insurance
Non-Life Insurance

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What Are the Holder/Companies Beliefs When it Comes to Unclaimed Property Reporting?

Whenever you inquire about Holder and their unclaimed property reporting, their responses are normally:
– We don’t have any unclaimed property to report or remit.
– We already file our unclaimed property reports, but they are normally negative/zero reports (reports showing nothing to report).
– Our outstanding checks list have been reviewed and none of them reflect any outstanding checks.
– Any small dollar amount outstanding checks (ie. < $5.00) are written off.

Any of these myths can increase your risk of an unclaimed property audit.

For further clarification on any unclaimed property compliance issues, please reach out to a professional at PEACC.com at 410.303.5510 or email us at info@peacc.com

Call PEACC for Compliance
Call PEACC for Compliance 410.303.5510

How Can A Company/Holder Be Reporting Their Unclaimed Property And Still Be Non-Compliant?

*  By reporting with incorrect dormancy periods or cut off dates.
*  Have a lapse(s) in the reporting periods/history.
*  By applying the wrong aggregate amount.
*  Simply reporting all property to only one State / State of Incorporation.
*  By misunderstanding the rules of customer generated contact / indication of Owner interest.
*  By not performing all State required Due Diligence / Search Letter specifics within the applicable time periods.
*  By not reporting property below a certain dollar amount.
*  By failing to report all eligible property / under reporting.
*  Submitting the report in the incorrect format.

For further information and assistance on how to stay compliant with the State specifics, please reach out to a professional at PEACC.com by calling us at 410.303.5510 or through email info@peacc.com

Call PEACC for Compliance
Call PEACC for Compliance 410.303.5510

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

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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