■ Apply to participate in the VCP & receive approval from State(s).
■ Complete any training requirements if offered by State.
■ Review books, records & property types.
■ Complete State required Holder due diligence/search letters.
■ Generate unclaimed property report(s) in proper format and submit.
■ Include remittance check or Electronic Funds Transfer specifics.
■ Address follow-up questions by the State(s), if any.
Below is a comprehensive breakdown of the essential steps required to successfully navigate a VCP.
Phase 1: Application and Authorization
The journey begins with a formal application to the state’s Unclaimed Property Department. Most states require you to demonstrate that you are not currently under audit and have not received a notice of an upcoming examination. Once you submit your intent, you must wait for formal approval. Some states also provide or require training sessions or webinars to ensure holders understand the reporting standards and the specific legal requirements of that jurisdiction.
Phase 2: Internal Review and Data Scrubbing
Once accepted, the heavy lifting begins with an exhaustive review of books and records. This involves:
- Identifying “dormant” accounts, uncashed payroll checks, or outstanding credits.
- Categorizing items by property type (e.g., wages, vendor checks, or mineral proceeds).
- Determining the “look-back period” defined by the VCP agreement.
Phase 3: Statutory Due Diligence
Before reporting the property to the state, holders must perform due diligence. This involves sending formal search letters to the last known address of the owner. This is not just a courtesy; it is a legal requirement. These letters give the owner a final opportunity to claim their property before it is remitted to the state.
Phase 4: Reporting and Remittance
After the due diligence period expires, any remaining unclaimed property must be compiled into a State-compliant report. Most states require the NAUPA II format. This report is submitted alongside the remittance, which can be sent via physical check or Electronic Funds Transfer (EFT).
Phase 5: Finalization
The process concludes with addressing any follow-up inquiries from state administrators. Once the state is satisfied with the report and the payment, they will typically issue a closing letter or a release, providing the company with a “clean slate.”
For further information regarding the participation in a State unclaimed property VCP, please reach out to a professional at PEACC to fully understand the specifics by calling 410.303.5510 or email us at
info@peacc.com
