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

Unclaimed Property Audits & Reviews

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

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

PEACC.COM FREE UNLAIMED PROPERTY CONSULTATION 

PEACC is a leading provider of unclaimed property compliance solutions, helping companies of all sizes navigate the complexities of state regulations. We offer a range of services, from initial compliance reviews and report generation to audit defense and customized training programs. Our goal is to provide effective and cost-efficient solutions that minimize risk and ensure compliance with all state requirements.

We understand that unclaimed property compliance can be challenging, and we are committed to providing our clients with the support they need to succeed. Our team of experts has extensive experience in all aspects of unclaimed property, and we are dedicated to staying up-to-date on the latest regulations and best practices. We believe in building long-term partnerships with our clients, providing ongoing support and guidance to ensure their continued success.

Contact PEACC today. at 410.303.5510, to schedule a FREE consultation and learn how we can help your company achieve and maintain full compliance with unclaimed property laws.

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

The Ins & Outs of State Reporting Unclaimed Property Due Dates

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
Call PEACC for Compliance 410.303.5510

How Can You Be Filing Your Unclaimed Property Reports and Still Not be Compliant?

1) By using an incorrect dormancy period or cut off date.

2) By reporting all property to the wrong State or State of Incorporation.

3) By having lapses in your reporting history.

4) By not understanding the rules of customer generated contact or interest in property.

5) By failing to report all eligible property

6) By not performing the State required Due Diligence/Search Letter function.

7) Under reporting or not reporting all property types.

8) Not using the State mandated required report formats.

For further assistance with non-compliance reporting issues, please contact a professional at PEACC at 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

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