November 19, 2020 peaccadmin

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

What Unclaimed Property Is Required To Be Reported?

Over 100 Different Property Types
Depending on the Industry

Main Property Types
Account Payables/Vendor Checks
Account Receivable/Credit Balances
Payroll Checks

Any Check or Obligation that Goes
Unclaimed/Uncashed/Dormant

When Are Reports Required To Be Submitted?

Depending on the State and Property Type
Normally 3 or 5 Years After
Property Has Been Unclaimed/Uncashed
Check Issue Date
Account Opened Date
No Activity
Payroll Checks
1 Year in Most States

After Due Diligence/Search Letter Mailing is Done
Normally 60 or 90 – 120 Days Prior to Report Due Date

State Reports Are Due Every Year/Annually
Corporations and Banks/Financial Institutions/Other
Normally by October 31.November 1
About 6 States Due in Spring/Summer
Insurance Industry
Normally by April 30/May 1

Where Are Reports Required to Be Submitted?

Report to the State of the Owner/Payee Last Known
Address as Reflected on the Company/Holder’s Books
and Records. –
-OR-
If Property is Unknown, Foreign or no State Law
addresses It,, Property Defaults to Company/Holder’s
State of Incorporation.

Why Is Unclaimed Property Required To Be Reported?

1965 U.S. Supreme Court Decision Texas v. New Jersey
Unclaimed Intangible Property is Required to be
Reported to the State of the Owner’s Last Known
Address – OR-
If address is Unknown, Foreign or State Law
Exempts it, Property Defaults to Holder’s State of
Incorporation

States May Assess Fines and Interest Penalties on Past
Due or Unreported Property
Fines and Penalties May Be Assessed For
Failure to Report/Remit Property
Failure to Comply with State Statutes
Interest Generally Ranges From 4%-25% of
Property Value
Criminal/Civil Penalties for Failure to
Report/Remit/Deliver Property

Filing a Fraudulent Report May Include
$100 – $200 per Day ($10000 Maximum)
Varies From $1000 – $25000 Fine Plus Some States
Assess An Additional 25% of the Property Value
Some States Include Class B Misdemeanor in Their Laws

How To Report Unclaimed Property?
Do it yourself
Various Software Solutions Available on Market
Manually using State’s websites
Co-Source/Outsource to a Service Provider
Either Partial or Full
State requirements
Via State Websites
In Required NAUPA II Electronic Format
Paper Reports Accepted if Less Than State
Threshold
Reports on CD’s if State Accepts It
Remittance/Payment Requirements
Via Check
Online Payments Via State Website
Via EFT/Wire Transfer if Over Certain Threshold

For further information or questions, please contact PEACC at 410.303.5510 or email info@peacc.com


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