State Reporting Formats & Remittance

All States require reports to be generated and submitted along with the remittance. Here are a few specifics that are required by certain States:

Stata Unclaimed Property Report Reminders:

~ Some States require the reports submitted to them be Notarized. Others require a specific Officer of the company (CFO/Comptroller) to sign them, certifying the report is accurate to the best of their knowledge.

~ All States required their reports are generated and submitted in the National Association of Unclaimed Property Association (NAUPA) format.

~ The majority of the States require Negative Reports be submitted when there is no property due to be reported for the year. Please note: submitting back to back Negative Reports may result in a unclaimed
property audit or State inquiry.

~ Can the State report be uploaded through the State website or does it need to be generated as a hard paper copy or CD and physically mailed into the individual State?

State Report Remit Specifics/Reminders:

~ Does the State accept payment for cash type property in: Check, ACH Payment or an Online Payment?

~ Securities related property:  Does the State require up front/advanced notification?

~ Specifics payment of any reported Tangible related property or Bank Safe Deposit Box Contents.

For further explanation of State Reporting & Remittance specifics, please reach out to a professional at PEACC.com by calling 410.303.5510 or email us at: info@peacc.com

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

Minimize UP Exposure

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

UP Compliance Reviews

States Performing Formal Unclaimed Property Reviews –

There are currently only a handful of States conducting Formal Unclaimed
Property Reviews. To successfully complete one of these Reviews, the
following areas should be investigated and analyzed:

–  Any written Unclaimed Property policies & procedures.
–  Expectations about how certain Property types are handled/reported.
–  Reporting history of all entities including acquisitions & divestitures.
–  How are outstanding/uncashed checks treated on closed bank accounts?
–  Any De Minimus policies or rulings?

Call PEACC for Compliance
Call PEACC for Compliance 410.303.5510

How States are increasing enforcement and compliance with the State Unclaimed Property laws and regulations

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
Call PEACC for Compliance 410.303.5510

What to Expect during your self-audit

Been given the option to perform a self-audit or review vs a state or state sponsored 3rd-party unclaimed property audit?

Here’s what to expect during your self-audit/review.

– The States allow less time to complete a self-audit/review vs a full fledged State sponsored audit to be completed.
– The States expect a thorough review of the company’s books & records for the entire lookback period. Normally 10 years plus the dormancy period.
– The State will utilize a State sponsored 3rd-party auditing firm to assist is gathering information and reviewing it.
– State report submission is normally done through a State webpage portal in a specific, State approved, format.
– If, after adequate testing and reviews are completed, Self-Audits can be completed fairly quick and without too many headaches.

For help with self-audits 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

Consequences for Not Having a Unclaimed Property Program

Consequences for Not Having a Yearly Unclaimed Property Compliance Process in Place.
There are harsh implications for Holders who do not have a annual unclaimed property compliance program including:

– For Holders who do not submit annual unclaimed property reports
– For Holders who file inconsistent, inaccurate or non-compliant annual reports
– Not reporting all property types in reports
– Filing annual unclaimed property reports late
– Holders run the risk of being audited which could lead to hefty fines/interest rates and penalties

As you can see, identifying, monitoring, reporting and complying with all State unclaimed property reporting laws & requirements are very important functions to have implemented within your organization.

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

Property Escheatment And Compliance Consulting
Property Escheatment And Compliance Consulting

What Makes Up Your Yearly Unclaimed Property Process?

~ 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
Call PEACC for Compliance

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