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UPPO Asks: How do you raise the profile of unclaimed property compliance in your company?

Posted By Administration, Thursday, August 3, 2017

Periodically, UPPO asks members to respond to a question, sharing their ideas, insights, and experience. The recurring UPPO Asks feature is a compilation of their responses. 


We recently asked several members: How do you raise the profile of unclaimed property compliance in your company?


“I met with leaders and staff in departments that produce unclaimed property items. I explained the importance of keeping good records and following up on unresolved items as soon as possible. Through these meetings, we identified areas for improvement and implemented process changes to reduce the number of items from becoming unclaimed property. I ask other groups to include me when establishing new programs and processes to make sure potential unclaimed property issues are addressed and become part of the new plan. The high rate of retirements is causing a higher than normal turnover in staff. As a result, I set up short meetings with new leaders in departments that produce unclaimed property to make sure they understand the process. I also contact the leader when I hear of something in the works that may affect unclaimed property to make sure I am included from that point forward. I do my best to be proactive, and that takes good communication.”—Jeannie Matthews, unclaimed property administrator, Idaho Power Company



“We have monthly meetings with our corporate director of finance to review internal processes and to discuss state regulatory updates. Our director of finance also holds meetings with our controllers to review UCP processes and ensure compliance. Our audit team sends an annual compliance questionnaire that requires our business areas to provide proof of UCP compliance and their sign-off. In the past, we sent out quarterly newsletters to provide UCP updates and processes.”—anonymous



“Our most effective approach to raising the profile of UP compliance is to raise the profile of the entire area of unclaimed property. Early on, we enlisted a ‘sponsor’ (actually the vp of tax) to assist us with projects to initiate compliance. This has evolved into a steering committee (essentially C level executives), which can help us remove obstacles and handle escalations as needed.


“Beyond the power of the C-suite, communication and education are key. I tap into every internal newsletter with articles—since there is always a need for content. I arrange training sessions and webinars for a variety of audiences—from educating the steering committee on new requirements to training operational groups on to how to better meet the requirements for compliance. It is impossible to overeducate/overcommunicate! We talk about audit potential and audit defense to be built into our processes. Working in a company where ethics and compliance are both deep in the culture helps to validate our efforts.


“We are actively embedding processes to move potential escheatable items into a pre-escheat account and out of the hands of the operational groups. This greatly reduces the complexity of compliance (at least for the supporting teams) and gives the UP team greater visibility and control.


“I think the final piece of raising visibility is the same networking that helps in every area of business. There is nothing that can replace having relationships with solid contacts. These folks become ambassadors within their own organizations. My contacts range from internal audit to controllers to AP/AR analysts, and everyone in-between. It becomes much easier to get results when people know you!”—Charlotte S. Kirk, manager, unclaimed property, ABB Inc.



“Raising the profile of unclaimed property is always a challenge. Audit notices and the need to file a VDA definitely gets attention, though not in a preferred manner. I find that quantifying the potential exposure of accounting methods and procedures is the best means of focusing user groups on the UCP process. It all boils down to dollars and cents, and persistence.”—Pam Runkel, CPA, indirect tax manager, ADT LLC



“I’ve worked at several (11) different companies over the last 30 years, and have been involved in unclaimed property for 20+ of those years. I’ve started the process in two companies, and enhanced the process in three companies. One company didn’t want anything to do with UCP at all.


“I think the best way to get the message across of the importance of UCP compliance is to have an ally in your department that has access to the C-suite. But to get that audience, you must have supporting documentation to show the potential audit exposure, which is a moving target at best. If you can show that this compliance is a value-added proposition, i.e. refunds from the states, limiting audit exposure, then this will help as well.


"This is only the beginning of the journey. Once you get the C-suite buy in, then you must get the other players on board to help with gathering the documents, payroll, A/P, A/R, benefits, accounting, etc.”—Mike Marion, CMI, senior manager indirect tax, Fruit of the Loom Inc.



Now it’s your turn. What do you think are the most important personality traits for an unclaimed property professional? Add a comment to this post to share your response.



Tags:  Compliance  unclaimed property  UPPO Asks 

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