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Unclaimed Property Focus
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UNCLAIMED PROPERTY FOCUS is a blog written by and for UPPO members, featuring diverse perspectives and insights from unclaimed property practitioners across the U.S. and Canada. We welcome your submissions to Unclaimed Property Focus. Please contact Tim Dressen via with any questions about submitting a blog post for consideration and refer to our editorial guidelines when writing your blog post. Disclaimer: Information and/or comments to this blog is not intended as a substitute for legal advice on compliance or reporting requirements.


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GAO Report Spotlights Unclaimed 401(k) Plan Tax Treatment Uncertainty

Posted By Administration, Wednesday, February 27, 2019

In May 2018, the Internal Revenue Service issued Revenue Ruling 2018-17, stating that IRA holders must withhold 10 percent federal income tax and issue form 1099Rs when reporting unclaimed IRAs to the states. The deadline for doing so was originally set at Jan. 1, 2019, but was later extended to Jan. 1, 2020. 


In February 2019, the tax treatment of unclaimed retirement accounts was in the spotlight again, but this time the accounts at issue were 401(k) accounts. The U.S. Government Accountability Office issued a 59-page report, Federal Action Needed to Clarify Tax Treatment of Unclaimed 401(k) Plan Savings Transferred to States. 


Based on information learned, in part, by surveying the states, IRA transfer agents and 401(k) plan service providers, the GAO reached several conclusions:

  • Although the IRS and Department of Labor have issued guidance on transferring retirement savings to states, the IRS has not clarified certain responsibilities or ensured that the retirement savings that owners claim from states can be rolled over into other tax-deferred retirement accounts. 
  • The IRS has not specified whether 401(k) plan providers should report state transfers as distributions and withhold federal income taxes. 
  • 401(k) plan provider practices vary. Some providers withhold taxes when transferring savings to states while others do not. This makes the IRS less likely to collect federal income taxes that may be due if transfers are taxable events. 
  • The IRS has not taken action to ensure that individuals who claim 401(k) savings from a state can roll over these savings to other tax-deferred retirement accounts. The IRS allows individuals to roll over savings after 60 days for several reasons, none of which include claiming 401(k) savings from a state. Account owners who are unable to roll over their reclaimed savings forgo the opportunity to continue investing the funds on a tax-deferred basis. 


The report includes three recommendations:

  1. The IRS Commissioner should work with the Department of the Treasury to consider clarifying whether transfers of unclaimed savings from employer-based plans (such as 401(k) plans) to states are distributions; what, if any, tax reporting and withholding requirements apply; and when they apply. 
  2. The IRS Commissioner should work with the Department of the Treasury to consider adding retirement savings transferred to states from terminating defined contribution plans to the list of permitted reasons for rolling over savings after the 60-day rollover period, in a form consistent with the rules adopted on the taxation of transfers of unclaimed retirement savings. 
  3. The Secretary of Labor should specify the circumstances, if any, under which uncashed distribution checks from active plans can be transferred to the states. 


The IRS and DOL are not obligated to respond to the GAO’s recommendations, so specific action resulting from the report remains uncertain.


Read the full GAO report

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2019 Spring Reporting Guide

Posted By Administration, Wednesday, February 20, 2019

Spring reporting season is again upon us. Several states require holders to file reports between March 1 and July 1. Following are reporting deadlines for these states, along with helpful links. This list is not exclusive to a specific holder industry, so please check the states’ websites for information on industry-specific reporting information and deadlines. 


Note: Tennessee was previously a spring reporting state but has since moved its filing date to fall. Details


Report due: March 29, 2019
Extensions: Extensions may be requested.

Contact: Maria Greenslade: or (860) 702-3125
Connecticut holder resources 


Notes from UPPO’s state administrator survey:

  • Holder instruction manual has been updated in the past three months.

Report due: March 1, 2019
Extensions: Extensions may be requested.

Contact: or (302) 577-8782
Delaware holder resources.


Notes from UPPO’s state administrator survey:

Report due: April 30, 2019
Extensions: Extensions may be 

Contact:, (850) 413-5522
Florida holder resources.

Report due: May 1, 2019
Extensions: Extensions may be requested.

Contact: Email form, (800) 961-8303
Illinois holder resources.



Report due: July 1, 2019

Extensions: No details provide.


Contact: or (517) 636-6940

Michigan holder resources.


Notes from UPPO’s state administrator survey:

  • New website URL:
  • Updated holder instruction manual/handbook expected soon.
  • Holders can now report properties and remit payments electronically.
  • HDE files no longer accepted.
  • Holders are expected to provide as much identifying, verifying information as possible. Without all information, claimants sometimes are referred back to holders for verification purposes.
  • Holders with nothing to report are able to submit a zero/negative report online. 
  • Because CEPAS has changed its company ID, holders will need to update their information with a new number provided on the payment website. 
  • EFT is required at the time of filing.


New York 
Report due: March 10, 2019
Extensions: Extensions may be requested. 

Contact: or (800) 221-9311
New York holder resources.


Notes from UPPO’s state administrator survey:


Report due: April 15, 2019
Extensions: Extensions may be requested.  

Contact: or (800) 379-3999
Pennsylvania holder resources. 


Report due: July 1, 2019

Extensions: Does not accept extension requests.


Contact: or (800) 321-2274

Texas holder resources.


Notes from UPPO’s state administrator survey:

  • Holder instruction manual has been updated in the past three months.


Report due: May 1, 2019
Extensions: Extension requests may be submitted to the Unclaimed Property Division of the State of Vermont Office of the Treasurer. Describe the circumstance(s) for the delay and indicate the anticipated report delivery date.

Contact: or (802) 828-2407
Vermont holder resources.

For detailed information about reporting deadlines, dormancy periods, due diligence requirements, exemptions and deductions, electronic filing and much more, UPPO members can refer to the Jurisdiction Resource Guide

Tags:  spring reporting  unclaimed property 

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UPPO Asks: Unclaimed Property Misperceptions​

Posted By Administration, Thursday, February 14, 2019

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: What is the most noteworthy or most frequent misperception you’ve heard about unclaimed property? 


“The most noteworthy misperception I hear is that and states’ websites are the only places to check for claimable unclaimed property.”—Paul Janisko, CEO, CoreUCP



“Most people think of unclaimed property as lost stuff, like umbrellas. They do not understand how that could pertain to my company.”—Amy Soler, administrative assistant, tax department, Solvay Business Services



“Sometimes it is challenging to convince management that the due diligence and other unclaimed property reporting requirements must be followed. Once I took a boss to an unclaimed property presentation provided by the state in order to show that the company needed to follow the unclaimed property rules. Many people that I speak with are still unaware that unclaimed property reporting rules exist. I have stated many times to colleagues who work at other companies, ‘No, you can’t write off old, uncashed checks.’”—Ruby Spiller, senior GL accountant, Infineon Technologies Americas Corp.



“A misperception on the work end of it would be that it’s easy. People within my company that I have talked to don’t realize how much work actually has to go into it. They just assume I throw a report together and send it off, when there is much more to it.”—Amy Lagunero, accounts payable specialist, Mortgage Guaranty Insurance Corporation



“The two most common misperceptions I’ve heard are: 1. As a holder, you only have to file in the states in which you operate; and 2. There is a uniform law that most states adopt. The reality is quite the opposite.”—Missy Key, vp – accounting, America First Credit Union



“1. Owners don’t realize how complicated the process is for getting escheated funds back from the state. Even when all of the required documentation is provided to the state by the owner, it can take years for the owners to get their funds back, if they are able to get them back at all.


"2. You don’t have to claim unclaimed property on taxes or as income.


"3. Owners don’t realize that their funds are sent to the state after the dormancy period. They often think that we just hold the money forever until they ask for it.”—Courtney Papinchak, accounting manager, Anadarko Petroleum Corporation



“The most frequent misperception I find for holders is the discounting of the gravity of their compliance responsibilities, recognition of its application and the degree of their potential exposure.


“The most frequent misperception I find for owners is that when searching for their properties they need to utilize searches for all name combinations, including aliases, in as many jurisdictions as possible, especially those individuals whose surname may also be a first name.”—Mark Watters, owner, Watters Unclaimed Property Consulting LLC



“They don’t think it affects them so they don’t care about unclaimed property.”—Susan Maul, senior manager, indirect tax, Arris International PLC



“The misperception I have often heard is that if someone is owed money from a company they would somehow be found. At this point, I gently explain that most often if the payee has changed address several times, or their last name has changed or whatever other circumstance applies, it becomes very difficult to track an individual – especially if no unique identifier is available, like a SSN or date of birth. I have personally experienced this many times as an escheat administrator since we do not collect SSNs or DOBs from our clients. 


“Another misperception I have heard of is if a due diligence letter is not returned by the U.S. Postal Service that means that the owner has received it and funds should not be escheated. Again, I gently explain that just because a due diligence letter was not returned undeliverable, we cannot assume that the owner received it. Since no response has been forthcoming from the owner, it is safe to assume that funds should be escheated.”—Antoinette Di Dato, accounting – compliance, GreenbergTraurig, P.A.



“One of the biggest noteworthy things in working for a TPA is that I rely heavily on our adjusters to contact claimants and providers when a check becomes stale dated. I am frequently asked to void checks because a claimant/provider is not able to be contacted or due to not having a current address. This is frustrating from my end because I know I am sending out due diligence letters to the wrong address, which means I’m not giving the state ‘good’ information when filing.”—Eric Nesbitt, accounting supervisor, Cannon Cochran Management Services, Inc.



“I guess the most frequent misconception is that once funds are moved to an unclaimed liability account, the business’s normal policy and procedures are eliminated. For instance, if the funds are related to a death claim, the misconception both internally and externally is that the death claim paperwork is no longer required in order to pay the funds out to the owner.”—Tony McDowell, senior accountant, American Equity Investment Life Insurance Company



“Common misperceptions in the oil and gas industry are that the states do not want every penny – for instance, only $50 and above; and that the states keep the money after a certain number of years of being unclaimed.”—Joni Byrd, senior advisor – land administration, EnerVest Ltd.



“The most frequent misperception I’ve heard about unclaimed property is individuals accept full responsibility for the recovery of unclaimed funds. If the statement were true, there wouldn’t be billions of dollars sitting on general ledgers of many companies. I believe some people don’t know the funds are there. Some think the funds are so small they aren’t worth the time and effort. Some don’t believe unclaimed property has anything of value. They believe it is a scam. But, I believe each fund-matters – each one has worth – each has a right to be claimed, and when added together the sum is astonishing.”—Monica Johnson, escheatment/unclaimed property manager, United Parcel Service



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:  unclaimed property  UPPO Asks 

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Developing a Strategy for Effective Asset Recovery

Posted By Administration, Wednesday, February 6, 2019

Unclaimed property compliance is a necessary, but expensive responsibility for many companies. However, unclaimed property professionals can help offset some of the costs associated with their role by taking on the holder. Seeking and recovering property owed to the company can turn an area that is normally a cost center into a profit center. 


Finding and claiming unclaimed property requires a well-planned and systematic effort. Some states publish unclaimed items only when they’re over a certain age or dollar amount, but these thresholds aren’t consistent from state to state. In addition, searchable data excludes a substantial amount of property held by cities, counties and other entities.


The complexities associated with a company’s structure and history compound these challenges. Property may not be listed only under the company’s current name. There may be property attached to numerous subsidiaries and other entities with different names, plus additional companies, subsidiaries and entities tied to mergers and acquisitions. Don’t forget about alternate spellings (or misspellings) and acronyms. 


Once property is located, recovering it can also prove challenging. Demonstrating that the property rightfully belongs to your company and that you have the authority to claim it carries another set of roadblocks. 


So, how should an unclaimed property professional approach this complicated task? Following are a few tips for making the process less cumbersome. 


Understand your company 

Having a comprehensive knowledge of your company’s business activities, holdings and history can help clarify the types of unclaimed property it is likely to have. Similarly, knowing the company’s legal names, DBAs, and merger and acquisition history is essential to conducting complete and effective unclaimed property searches. 


"To maximize recoveries, you must know your company,” said Kim Sawyer, consultant for PricewaterhouseCoopers. “Understand your M&A history, learn your corporate structure, identify all fictitious and previous names, appreciate your primary business lines and ascertain significant physical locations. Based on that information, create search and source lists. A search list consists of legal entities and fictitious name under which unclaimed property may be found. A source list narrows down where you are going to do these searches, based on clients, vendors and agencies that may owe you a refund.”


Build a reference library

Unclaimed property claims frequently require documents that verify the company’s relationship to its subsidiaries and predecessor companies. Maintaining a library of these documents makes the process easier and more efficient. The library should include: merger and acquisition filings, name change and fictitious name filings, an Internal Revenue Service letter containing the tax ID number, and a list of current and past real estate holdings.


Typically, the person signing for the unclaimed property must demonstrate the authority to do so. Depending on the holder or agency, proof may be as simple as company bylaws, but in many cases a secretary certificate or other specific documentation will be required. The signatory usually needs to provide a driver’s license for identity verification as well. 


“If you’re searching for a predecessor company that no longer exists, you’ll need documentation that the company was 100 percent owned by your company before it dissolved and, in some cases, you may have to legally revive the company before a source may pay out a claim,” Sawyer said. “When dealing with acquisitions, you’ll need to show documentation that your company is entitled to recover property that exists under the predecessor company’s name. Maintain these documents in an organized fashion because you’ll have to access them repeatedly.”


Get organized

A well-designed unclaimed property recovery system includes a thorough tracking document or database containing detailed, up-to-date information about searches, data requests and submitted claims. It should include property IDs, amounts, owner names and addresses, contact names and phone numbers, and scheduled follow-up dates.


Exercise care with third parties

If your company decides to seek assistance from a third-party specialist, perform due diligence to ensure you’re dealing with a reputable firm. Make sure you have a detailed explanation of the fee structure before signing any agreements. 


“It’s important to conduct background checks when considering a relationship with a third-party vendor,” said Donna Greenhalgh, unclaimed property supervisor with AT&T. “Seeking recommendations and feedback from other departments within your company may also be beneficial, since they may be using vendors that perform services for other purposes, such as tax services or audit support. Checking to see if they are UPPO members is also another worthwhile step.” 


Join UPPO for an in-depth look at recovering unclaimed property during the Recovering Assets for Your Company webinar at 1 p.m. EST on Feb. 13. Presenters Kim Sawyer and Donna Greenhalgh will provide insight and practical tips to help unclaimed property professionals find and recovery assets for their companies. Register today

Tags:  asset recovery 

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UPPO Advocacy Update: January 2019

Posted By Administration, Thursday, January 31, 2019

To help members remain aware of UPPO’s advocacy activities, the Unclaimed Property Focus blog recently began including a recurring Advocacy Update when legislatures are active or significant advocacy activity has occurred. Following are recent activities and trends from UPPO’s Government Relations and Advocacy Committee (GRAC).


More States Consider RUUPA-Inspired Legislation

With state legislatures back in session, it’s not surprise new RUUPA-inspired bills have begun moving. 


In Colorado, S.B. 88 would significantly revise the state’s unclaimed property statutes, including shortening of some dormancy periods and changes due diligence and reporting requirements. The bill has been assigned to the Business, Labor & Technology Committee for review. 


Likewise, Washington H.B. 1179 would update the state’s unclaimed property statutes, including provisions covering presumptions of abandonment, reporting requirements and due diligence requirements. The bill is scheduled for a Finance Committee hearing on Jan. 31.


A Noteworthy Trend

Two bills – North Dakota H.B. 1187 and Oregon S.B. 454 – would move administration of their states’ unclaimed property functions from the land commissioner and Department of State Lands, respectively, to the state treasurer. It’s not known whether this legislation was promoted by the National Association of State Treasurers, but the simultaneous consideration of two bills with essentially the same goal seems noteworthy.    


Priority Issue Workgroups

In preparation for the new congressional session, the GRAC Priority Issue Workgroups are finalizing talking points and single-page position papers about key issues. These materials will be used to help consistently demonstrate support or opposition of state legislation that is likely to affect unclaimed property compliance. 


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 network. Responses will give us the ability to mobilize UPPO members when we are faced with legislative and regulatory challenges and opportunities.



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