– Corporate structure – Current and previous Chart of Accounts – Review of Accounts that May Hold Uncashed Property – Review of General Leger Trial Balances – Any previous State unclaimed property reports. – Any past audit reports & results – Outstanding check listing of all disbursement accounts – Accounts Receivables aging report – Journal entries related to write-offs and any details – Descriptions and any contracts related to any third-party administrators – Any mergers & acquisitions reports and detail
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 410.303.5510
The Ins & Outs of State Reporting Unclaimed Property Due Dates February 17th, 2025peaccadmin
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.
Unclaimed property in the corporate world typically refers to intangible property and are funds owed to another party that have remained unclaimed or uncashed for a specific time period. Normally a period of one, three or five years, known as the dormancy period. After this dormancy period expires, the property is required to be reported and remitted to the Owner’s State of last know address or State of Incorporation if the address is unknown. – The property must be fixed and under certain legal obligations. – The States take custody of these unclaimed funds and hold the property until the rightful Owner comes forward to claim them. – All States have reporting requirements including D C , Guam, Puerto Rico & the Virgin Islands. – Unclaimed Property Reporting is NOT a tax – traditional NEXUS does not apply.
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 410.303.5510
How States are increasing enforcement and compliance with the State Unclaimed Property laws and regulations January 23rd, 2025peaccadmin
Now that your fall unclaimed property reporting is complete, your PEACC Team of Advisors would like to announce Delaware is schedule to send out the next round of VDA invitations on November 15, 2024. The State last sent invitation letters out in February 2024.
If your organization receives a VDA (Voluntary Disclosure Agreement) invitation Letter from Delaware and fails to timely respond, you will become eligible for the dreaded, unclaimed property audit. Contact the professionals at PEACC to discuss your options, along with the process, at 410.303.5510.
When performing any unclaimed property self-audits or reviews, please keep two important givens in mind to alleviate troubles down the road:
1) Most companies will under estimate their true unclaimed property exposure if and when audited by the State(s).
2) A State will put the burden of proof on the Holder to prove they’re wrong. A State will presume a Holder is guilty unless they can be proven wrong.
For help in developing and implementing an annual unclaimed property reporting process 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
Unclaimed Property Self-Audits: Two things to always keep in mind January 23rd, 2025peaccadmin
~ 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
What Makes Up Your Yearly Unclaimed Property Process? January 14th, 2025peaccadmin
Your Total Source for Unclaimed Property Compliance
