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

A Formal Unclaimed Property Reporting Step Process

Prior to reporting any unclaimed property to the States, a formal set of
standard reporting procedures should be developed and followed
including:

1)  Identify and track all unclaimed property.
2)  Set up Liability Account/Spread sheet of all identified unclaimed properties.
3)  Calculate correct State dormancy periods. (most cases 1,3 or 5 years)
4)  Determine if any property may be exempt from State reporting.
5)  Mail out State required Due Diligence/Search letters during State mandated time frames.
6)  Prepare State reports in proper State formats.
7)  Submit reports & remittance to the appropriate State, normally thru the State website portal.
8)  Update records, including Liability account.
9)  Enjoy a cup of coffee, until next year!

Call PEACC for Compliance
Call PEACC for Compliance 410.303.5510

How to Successfully Complete the Voluntary Compliance Process (“VCP”):


– Apply for and receive approval for enrollment into the program from the VCP State.
– Complete any formal educational/training given by the State, if any.
– Review your books and records for unclaimed property.
– Preform and complete Holder required Due Diligence Mailings.
– Submit a preliminary “Notice” report to the State. If approved:
– Submit a final “Remit” report to the State along with any remittance.

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

TYPES OF UNCLAIMED PROPERTY AUDITS & REVIEWS

State Unclaimed Property Audit

    – done by individual State or can be done jointly with other State(s).

Reciprocal Audit

    – One State audits on behalf of other State(s)
    – Expenses and resources are shared

Private Audit Firms

     – State Contracts Out Third-Party Audit Firm
     – May Get Paid Based Upon a Percentage of What They Find

Telephone Audits & Reviews

     – State contacts Holder via phone.
     – Listen for uncertainties & inconsistencies in voice.

“Highway Audits”

     – State audit employees look for newspaper headlines, billboards and trucks while out of office for audit candidates.

For further information about the types of unclaimed property audits and how to navigate thru them,
please contact the experts at PEACC at 410.303.5510 or email us at info@peacc.com

Call PEACC for Compliance
Call PEACC for Compliance 410.303.5510

Examples of Unclaimed Property in the Corporate World

– Vendor or Accounts Payable Checks
– Payroll Checks or Denied Automatic Payments/Direct Deposits
– Refunds/Rebates
– Account Receivables/Credit Balances
– Customer Overpayments
– Unapplied Cash
– Unredeemed Gift Certificates
– Dormant Back Accounts (Checking/Savings Accounts)
– Life Insurance Proceeds Due
– Uncashed Benefit Checks

Call PEACC for Compliance
Call PEACC for Compliance 410.303.5510

What Is Unclaimed Property?

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.

Visit PEACC.com for more information.

Call PEACC for Compliance
Call PEACC for Compliance 410.303.5510

Delaware Unclaimed Property (VDA)

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.

https://lnkd.in/eTMSCMqp
VDA Invitation Dates – VDA Program – State of Delaware
vda.delaware.gov

State of Delaware map

Unclaimed Property Self-Audits: Two things to always keep in mind

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

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