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UPPO Advocacy Year in Review

Posted By Administration, Wednesday, January 8, 2020

UPPO’s Government Relations and Advocacy Committee (GRAC) had another busy year in 2019. 

Following is a review of key highlights of the advocacy work by GRAC and the Holders Coalition, a group of organizations, including and administered by UPPO, whose members hold or represent owners of property.



The GRAC Priority Issue Workgroups developed talking points and single-page position papers about key issues. These materials were designed to help consistently demonstrate support or opposition of state legislation that is likely to affect unclaimed property compliance. 



On March 31, 2019, UPPO along with organizations representing life insurers, bankers, shareholder services professionals and transfer agents submitted a letter regarding RUUPA-inspired legislation to the Minnesota Department of Commerce. The coalition raised several concerns with Article 13 of H.F. 2208 and companion bill S.B. 2611. The Minnesota legislature adjourned without action on these bills.



Seeking to refine its processes and operate as efficiently as possible, GRAC implemented a new structure consisting of four sections. The committee established responsibilities for each section and a process for section leaders to report to the GRAC co-chairs. The four GRAC sections are:

  • Issue Identification: Identifies important issues and determines legislative, regulatory and legal issues to address.
  • Strategy Implementation: Determines and ensures the execution of the strategy for addressing identified issues, working with legislators, regulators and other officials to promote UPPO’s position.
  • Position and Policy Drafting: Creates work product to support the strategy to promote UPPO’s position.  
  • Communication: Works with UPPO staff to update members and other stakeholders about advocacy initiatives.



With most state legislatures recessing or adjourning for the year, GRAC and the Holders Coalition continued to work on federal issues, including the Internal Revenue Service’s position on individual retirement account escheatment, the tax treatment of unclaimed 401(k) accounts highlighted by the recent GAO report, and the SECURE Act. GRAC also continued its work promoting introduction of a voluntary disclosure program in California



To make it easier for members to submit ideas and issues for the committee’s consideration, UPPO has added a form to the advocacy web page. Please use this form to share advocacy suggestions, ideas and issues for GRAC to consider. 



On Oct. 3, 2019, Bloomberg Tax published an article outlining potential unclaimed property issues that could result from a whistleblower case brought against JPMorgan Chase & Co., regarding the company’s unclaimed property practices. UPPO shared its concerns in the article about unintended consequences that could harm unclaimed property holders.


On Oct. 15, 2019, UPPO sent a letter to Texas Director of Unclaimed Property Joani Bishop and Assistant Director of Unclaimed Property Bryant Clayton, requesting clarification from the state regarding issues related to controlling interest, third-party vendors and combined reporting implementation contained in H.B. 3598. 


UPPO received a prompt response, accepting a request to discuss UPPO’s concerns. A subsequent call was held on Oct. 30, 2019, and additional email follow-up discussions have occurred, with Texas soliciting UPPO’s insight regarding its new unclaimed property holder website.



The Holders Coalition submitted comments on Nov. 19, 2019, to Internal Revenue Service and Department of Treasury officials regarding IRS Revenue Ruling 2018-17. The comments seek clarification and guidance regarding compliance with the ruling, issued by the IRS on May 29, 2018.


The Minnesota ULC commissioners convened a work group, including representatives from the Commerce Department, the unclaimed property administrator and stakeholders, to explore a state RUUPA bill. Holding discussions with all affected parties in this manner before an unclaimed property bill is introduced is rare. UPPO appreciates Minnesota taking this action and will continue to participate in these meetings.  



In response to California’s adoption of S.B. 109, UPPO submitted comments to the comptroller’s office regarding the law’s provision requiring development of a “one-time unclaimed property amnesty, or other options to increase compliance with unclaimed property law in lieu of an amnesty program, and options for increasing the return of unclaimed property to rightful owners.” UPPO spelled out reasons the state would benefit from an ongoing voluntary disclosure agreement program.


On Dec. 12, 2019, the Holders Coalition submitted comments to Colorado officials, highlighting practical issues and recommendations regarding implementation of S.B. 88, RUUPA-inspired legislation that goes into effect on July 1, 2020.


Let Your Voice Be Heard

As more and more legislatures and regulatory agencies take on issues affecting unclaimed property compliance, advocacy has become an increasingly important role for UPPO. Please take a few minutes to complete our Government Relations and Advocacy Survey to help us build our grassroots advocacy network. 


Responses will give us the ability to better provide you with the information you want and need, and will allow us to mobilize UPPO members when we are faced with legislative and regulatory challenges and opportunities. 

Tags:  advocacy 

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