unclaimed property compliance

04 Aug 2025
Sticky Post By Posted in D. Patrick ("Pat") Healy, Escheatment, Holder: Due Diligance Permalink

State Unclaimed Property Report Reminders

Sticky Post By On August 4, 2025

Holders/companies need to identify and track their unclaimed property with appropriate dormancy period. Then resolve liability with the property Owner or report the property to the appropriate State
jurisdiction before the end of the dormancy period, normally 3 or 5 years.

Key reporting questions to consider:

– Does the State require reports to be in the NAUPA standard format or something unique to that State?
– Are there any Due Diligence/Search Letter requirements?
– Is there a “Negative Report” requirement?
– Will the Unclaimed Property Report need to be Notarized or signed by a Company Official?
– Do State reports need to be uploaded via the State reporting website or mailed in on CD or a paper report?

– Remittance/Payment Instructions
    •  Cash Property – Submit a check or payment through ACH/Online Payment.
    •  Securities – Does the State require advanced notice/payable to instructions?
    •  Tangible/Safe Deposit Box property. Does the State require a special reporting form/instructions for Safe Deposit Box contents?

For questions about “How to report to each State along with special instructions”, please reach out to PEACC.com to ensure you are in compliance with all the State report requirements. Call us at 410.303.5510 or email at info@peacc.com

Call PEACC for Compliance
Call PEACC for Compliance 410.303.5510
07 Jul 2025
Sticky Post By Posted in D. Patrick ("Pat") Healy, Unclaimed Property Compliance Permalink

How Are States Enforcing Their Unclaimed Property Compliance?

Sticky Post By On July 7, 2025

–  Through State or State sponsored Compliance Reviews
–  Through formal State audit notices.
–  Self-Audit notices, including those conducted/sponsored by third party firms.
–  State reminder letters regarding Compliance with reporting obligations.
–  State VDA (“Voluntary Disclosure Agreement”) Invitations.
–  Automatic penalty & interest assessment for non-compliance.
– If you are contacted by a State regarding your compliance efforts, it is best to respond right away!

To discuss these State enforcement steps or any other issues relating to unclaimed property reporting compliance, please reach out to a professional 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
21 Jun 2025
Sticky Post By Posted in History of Escheatment Permalink

Unclaimed Property – Whats All The Fuss About? Visit PEACC.com

Sticky Post By On June 21, 2025

Although unclaimed property has been around for years, it is still a fairly new issue for some companies throughout the United States. Unclaimed property, also known as “escheat”, evolved during the days of English Common Law.

When an event disrupted the natural descent of property, such as no heirs, the property was “escheated” to the Lord of the Manor. Escheated property then became the sole property of the Lord of the Manor, and rightful heirs lost all claim to the property indefinitely.

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Evolution of Modern Day Unclaimed Property
Unclaimed property has come a long way from the days of English Common Law. In those days all unclaimed property was tangible, normally made up of land and stray animals, including  horses and cattle.

Today unclaimed property consists of intangible property, such as dormant bank accounts, uncashed checks,  unreturned deposits and credit balances. Unclaimed property normally falls under two separate categories, either general ledger property types, or securities related property.

Unclaimed property laws require reporting to the appropriate State jurisdiction, where each State has their own unclaimed property laws and regulations. Each State has specific due date(s) that unclaimed property must be reported by. The due dates are determined by dormancy period and type of property. Depending on the property type, the dormancy period, on average, ranges between one to five years.

Each State requires companies to perform this reporting process on an annual basis, along with the State mandated due diligence/search letter requirements.

Generally, and as a rule of thumb, most corporations, banks, and financial institutions are required to submit their reports and remittance by October 31 of each year.

Reports and remittance for most insurance companies are due by April 30 of each year. There are a few States where the reporting due dates may differ.

All States now act as custodians of this reported property and will turn the property back over to the rightful owner or heirs with true claims to it.

The goal on most State Unclaimed Property Offices is to get this unclaimed property back to the rightful owner’s hands.

Although, as history has it, on average maybe only 25% to 28% of this property is actually ever reclaimed and paid out by the States to the rightful owner.

15 Apr 2025
Sticky Post By Posted in D. Patrick ("Pat") Healy, Unclaimed Property Audits, Unclaimed Property Compliance, Unclaimed Property Consulting, Unclaimed Property Laws, Unclaimed Property Reporting Permalink

Unclaimed Property Audits & Reviews

Sticky Post By On April 15, 2025

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

Minimize UP Exposure

Sticky Post By On March 14, 2025

How Does a Company Minimize Their Unclaimed Property Exposure & Implement Best Practices?

– Ensure you are abiding to all State reporting deadlines and compliance calendars.
– Understand and abide to the various compliance rules and regulations along with your industry requirements.
– Establish and implement unclaimed property liability accounts. Update them monthly.
– Perform all State mandated due diligence/search letter mailings.  Stay on top of rules & requirements.
– Investigate and implement any possible outsource solutions.
– File reports annually & consistently as required. Maintain copies of reports.
– Document and maintain support of what you DO NOT owe the States.
– Maintain a log of State’s offering Voluntary Disclosure Agreements (“VDA”) and all specifics.
– Conduct periodic reviews of all functions.
– Assign personnel and define rolls.

Call PEACC for Compliance
Call PEACC for Compliance 410.303.5510

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