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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 tim@uppo.org 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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UPPO Asks: What has been the most noteworthy change within the unclaimed property profession during your career?​

Posted By Administration, Thursday, August 9, 2018

Occasionally, 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 has been the most noteworthy change within the unclaimed property profession during your career? 

 

“In an effort to raise revenue and balance their budget, states have been actively initiating audits, shortened dormancy periods, and use third-party auditors with aggressive audit practices. However, the most noteworthy change during my career is the landmark Temple-Inland, Inc. v. Cookcourt case, which challenged the state of Delaware’s unclaimed property audit practices. Not only did the case shed light on Delaware’s estimation methodology, but it also challenged its constitutionality.  

 

“Everyone in the unclaimed property community remembers where they were, when they first read the U.S. District Court for the District of Delaware’s opinion holding Delaware’s executive action of auditing and assessing a multistate corporation’s unclaimed property, violated substantive due process because the states action when taken together, ‘shock the conscience.’ Those words reverberated throughout the unclaimed property community for several months. 

 

In finding that the audit assessment ‘shock the conscience’ the court relied on six factors including the fact that the state waited 22 years to conduct the audit and circumvented the typical three- to six-year statute of limitations period. As a result of the court’s decision, Delaware overhauled its unclaimed property statutes and among other things reduced the look back period and limit the statute of limitations. This is a landmark case, because the court decision significantly impacted the future of unclaimed property audits not only by Delaware, but other states as well.”—Zenith Lewis, manager, federal taxes, Southwest Airlines Co.

 

 

“In my 15-year career, there have been significant changes from online reporting, vast amount of resources such webinars, conferences, and – most importantly for me – I was tasked by my current employer to find an organization that would allow me to grow in my position and I came across UPPO. UPPO has been that noteworthy change. I have formed many friendships within this wonderful organization, joined committees, gained a multitude of knowledge and taken advantage of the certificate program.”—Rolita Brownlee, supervisor, policy management, Geico Marine Insurance

 

 

“The most noteworthy change in my opinion is the unclaimed property voluntary disclosure program (VDA), which gives holders an opportunity to come into compliance with their legal responsibilities. It’s also a great tool to use for mitigating the risk associated with premerger due-diligence and post-merger remediation. The benefits of the VDA program are a limited look-back period, and waived or reduced penalties and interest on past due items.  

 

“We recently used the VDA program to report past due property picked up from an acquisition. In this instance, the unclaimed property reports were filed in a timely manner, but there were other issues such as a lack of complete records that were at a greater risk of being noncompliance. Fortunately, working with a third-party vendor, we were able to reduce both the initial obligation and interest penalties. 

 

“Now, that I’ve had that experience, I’m excited about the latest changes in Delaware that revise the earlier guidelines and no longer permit the state to initiate audits without first giving a company the opportunity to enter into the VDA program. Hopefully, this change will benefit holders, especially since the potential for a state audit is higher after a M&A.”—Alicia Douglas, unclaimed property specialist, business development, Ocwen Financial Corporation

 

 

“The change to online filing and the requirements has been a huge change. It remains a constant struggle to be up to date on the all compliance changes.”—Susan Greulich, unclaimed property administrator, GFSS–Global Financial Services and Systems, Eaton

 

 

“The most noteworthy change in unclaimed property over the course of my experience would be the impact of audits. They have not only brought unclaimed property to the table for consumers/clients, but for companies overall. When I began in unclaimed property, there were so few policies, procedures and best practices in place, as well as hardly anyone who could share their experience or guidance in the process. Now we are seeing unclaimed property commercials on TV, online advertisements, and conversations among those not directly involved, and that is such a good thing. The newfound awareness will not only help to create more effective procedures, policies, best practices, etc. but will also lend itself to more individuals that know what unclaimed property is, as well as how it should be handled. I think the industry will continue to grow and expand and we are just beginning to break the surface. I look forward to staying tuned to what is in store in the future and beyond!”—Jessica Rogers, analyst, treasury consultant, Lincoln Financial Group

 

 

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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2018 Fall Reporting Guide Part 4 (South Carolina – Wyoming)

Posted By Administration, Tuesday, July 31, 2018

Fall reporting season is again fast approaching. Most U.S. states require holders to file reports by either Oct. 31 or Nov. 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. Because of the amount of information included, this guide will be published in four parts:

 

Part 1 covers Alabama through Hawaii.

Part 2 covers Idaho through Minnesota.

Part 3 covers Mississippi through Rhode Island.

Part 4 covers South Carolina through Wyoming.

 

South Carolina

Report due: Nov. 1, 2018
Extensions: Extensions may be requested by email before the report due date.

 

Contact: unclaimed@sto.sc.gov or (803) 737-4771

South Carolina holder resources

 

Notes from UPPO’s state administrator survey:

  • South Carolina now requires negative reports be submitted via our website. Holders with only a few properties may also opt to create and submit a report on our website. 
  • ACH/Wire are the preferred method of payment. Checks will be accepted but must be accompanied by a Submission Confirmation form (available on our website).

 

South Dakota

Report due: Nov. 1, 2018
Extensions: Extensions may be requested in writing before the report due date.

 

Contact: holders@sdtreasurer.gov or (605) 773-3379

South Dakota holder resources

 

Notes from UPPO’s state administrator survey:

  • Instruction manual/handbook has been updated in the past three months.
  • Reporting portal has added the option to create your report online.
  • We cannot accept HDE files.

 

Utah

Report due: Nov. 1, 2018
Extensions: Extensions may be requested in writing before the report due date.

 

Contact: holders@utah.gov or (801) 715-3300, ext. 2

Utah holder resources

 

Notes from UPPO’s state administrator survey:

  • New URL: https://mycash.utah.gov/app/faq-report
  • Instruction manual/handbook has been updated in the past three months.
  • New manual online reporting. No HDE files allowed.
  • NO HDE files.
  • Worthless shares are no longer reportable.
  • DRPs must be sold and proceeds delivered to the state.
  • New landing site for reporting https://mycash.utah.gov/app/submit-a-report

 

Virgin Islands

Report due: Oct. 31, 2018
Extensions: No details provided.

 

Contact: (340) 774-7166

Virgin Islands holder resources

 

Virginia

Report due: Nov. 1, 2018
Extensions: Extensions may be requested.

 

Contact: William.Dadmun@trs.virginia.gov or (804) 225-2142 

Virginia holder resources

 

Notes from UPPO’s state administrator survey:

  • Instruction manual/handbook has been updated in the past three months.
  • Payment of any type is accepted and should be issued within two days of submitting your electronic file.
  • If a NAUPA file is submitted for the report data, and the remittance is submitted via ACH or wire transfer, then the AP-1 form can be submitted as a scanned document (after being signed and scanned) to Report.Remit@trs.virginia.gov. If you are reporting large numbers of tangible properties, and your software supports doing so electronically, you may now report tangible items in this manner. In the past we required paper reports for tangible reports. You should still set up the tangible reports as a separate report.

 

Washington

Report due: Oct. 31, 2018
Extensions: Extensions may be requested in writing before the report due date. Include company name, holder number, reason for extension request and amount of time requested.

 

Contact: ucp@dor.wa.gov or (360) 534-1502 or (800) 435-2429

Washington holder resources

 

West Virginia

Report due: Oct. 31, 2018
Extensions: Extensions may be requested.

 

Contact: UP-ReceiptsGroup@wvsto.gov or (800) 642-8687

West Virginia holder resources

 

Wisconsin

Report due: Nov. 1, 2018
Extensions: Extensions may be requested.

 

Contact: Email formor (608) 264-4594

Wisconsin holder resources

 

Notes from UPPO’s state administrator survey:

  • Instruction manual/handbook has been updated in the past three months.
  • Reports must be filed electronically. Reports on paper or CD will not be accepted.
  • In Wisconsin, holder reports can post automatically, making property available for claimants in as little as three days. Holder reports must be correct when submitted, as we may no longer have the property for you to file a claim for refund.
  • ACH payment methods preferred. See Wisconsin Holder Report Guide for details. WIRE payments are no longer accepted.
  • Unclaimed Property has been at the Wisconsin Department of Revenue for five years. However, holders continue to send paper reports to the Office of State Treasurer. Please note: DOR ONLY accepts e-filed holder reports, and our P.O. Box is 8982. The old P.O. Box associated with the Treasurer's Office has been closed.

 

Wyoming

Report due: Nov. 1, 2018
Extensions: Extensions may be requested in writing before the report due date.

 

Contact: upreports@wyo.gov or (307) 777-5590

Wyoming 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

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Title: 2018 Fall Reporting Guide Part 3 (Mississippi – Rhode Island)

Posted By Administration, Thursday, July 26, 2018

Fall reporting season is again fast approaching. Most U.S. states require holders to file reports by either Oct. 31 or Nov. 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. Because of the amount of information included, this guide will be published in four parts:

 

Part 1 covers Alabama through Hawaii.

Part 2 covers Idaho through Minnesota.

Part 3 covers Mississippi through Rhode Island.

Part 4 covers South Carolina through Wyoming.

 

 

Mississippi

Report due: Nov. 1, 2018
Extensions: No details provided


Contact: UPReporting@treasury.ms.gov or (601) 359-2513

Mississippi holder resources

 

Missouri

Report due: Nov. 1, 2018
Extensions: Extensions may be requested in writing at least 30 days before the reporting due date.


Contact: Email form

Missouri holder resources

 

Montana

Report due: Nov. 1, 2018
Extensions: Extensions may be requested.


Contact: UnclaimedProperty@mt.gov or (406) 444-6900

Montana holder resources

 

Notes from UPPO’s state administrator survey:

  • New website URL: https://mtrevenue.gov/property/unclaimed-property-holders/
  • Instruction manual/handbook has been updated in the past three months.
  • Payment should be mailed with payment voucher. No need to fill out UCH-1 form when submission is online.
  • New contact is Anna Walker: (406) 444-6917.
 

Nebraska

Report due: Nov. 1, 2018
Extensions: Extensions may be requested.


Contact: Email form

Nebraska holder resources

 

Nevada

Report due: Oct. 31, 2018
Extensions: Extensions may be requested.


Contact: nvholder@nevadatreasurer.gov or (702) 486-4140

Nevada holder resources

 

New Hampshire

Report due: Nov. 1, 2018
Extensions: No details provided


Contact: ap@treasury.state.nh.us or (603) 271-2619

New Hampshire holder resources

 

New Jersey

Report due: Oct. 31, 2018
Extensions: Extensions may be requested.


Contact: Email form or (609) 292-9200

New Jersey holder resources

 

New Mexico

Report due: Nov. 1, 2018
Extensions: Extensions may be requested.


Contact: (505) 827-0767 or (505) 827-0668

New Mexico holder resources

 

North Carolina

Report due: Nov. 1, 2018
Extensions: Extensions may be requested.


Contact: upreports@nctreasurer.com or (919) 814-4200

North Carolina holder resources

 

North Dakota

Report due: Nov. 1, 2018
Extensions: Extensions may be requested in writing before the report due date.


Contact: Email form or (701) 328-2800

North Dakota holder resources

 

Notes from UPPO’s state administrator survey:

  • Electronic reporting required for 2018. 

 

Ohio

Report due: Nov. 1, 2018
Extensions: Extensions may be requested.


Contact: UnfdClaims.UnfdClaims@com.ohio.gov or (614) 466-4433

Ohio holder resources

 

Oklahoma

Report due: Oct. 31, 2018
Extensions: Extensions may be requested in writing on company letterhead before the report due date.


Contact: holderinfo@treasurer.ok.gov or (405) 521-4273

Oklahoma holder resources

 

Oregon

Report due: Nov. 1, 2018
Extensions: Extensions may be requested.

 

Contact: holder@state.or.us or (503) 986-5200

Oregon holder resources

 

Rhode Island

Report due: Nov. 1, 2018
Extensions: No details provided

 

Contact: ups@treasury.ri.gov or (401) 462-7676

Rhode Island 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:  fall reporting  unclaimed property 

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2018 Fall Reporting Guide Part 2 (Idaho – Minnesota)

Posted By Administration, Tuesday, July 24, 2018

Fall reporting season is again fast approaching. Most U.S. states require holders to file reports by either Oct. 31 or Nov. 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. Because of the amount of information included, this guide will be published in four parts:

 

Part 1 covers Alabama through Hawaii.

Part 2 covers Idaho through Minnesota.

Part 3 covers Mississippi through Rhode Island.

Part 4 will cover South Carolina through Wyoming.

 


Idaho

Report due: Nov. 1, 2018
Extensions: Extensions may be requested before the report due date. 


Contact: UCPBusinessQuestions@sto.idaho.gov or (208) 332-2942 or (877) 388-2942
Idaho holder resources 


Illinois 
Report due: Nov. 1, 2018, for all banking and financial organizations, insurance companies (other than life insurance) and governmental entities
Extensions: Extensions may be requested at least 15 business days before the reporting deadline.


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

 

Indiana

Report due: Nov. 1, 2018
Extensions: Extensions may be requested at least 30 days before the reporting due date.


Contact: updholder@atg.in.gov, (800) 447-5598 or (317) 883-4520
Indiana holder resources

 

Iowa

Report due: Nov. 1, 2018
Extensions: Extensions may be requested at least 30 days before the reporting due date.


Contact: upreport@tos.iowa.gov or (515) 281-7546 
Iowa holder resources

 

Kansas

Report due: Nov. 1, 2018
Extensions: Extensions may be requested.


Contact: KSHolder@treasurer.ks.gov or (785) 291-3173
Kansas holder resources

 

Kentucky

Report due: Nov. 1, 2018
Extensions: Extensions may be requested.


Contact: Unclaimed.property@ky.gov or (800) 465-4722

Kentucky holder resources

 

Notes from UPPO’s state administrator survey:

  •  Instruction manual/handbook has been updated in the past three months.
  • We want holders to keep checking on our website. We hope to have an import tool ready to use before the Nov. 1 reporting deadline.
  • Watch our website. We hope to have the import tool ready by Nov. 1 and will be able to process ACH payments.
  • Kentucky is not requiring Negative Reporting this year. New RUPPA laws are in effect for 2019 reporting season.

 

Louisiana

Report due: Oct. 31, 2018
Extensions: Extensions may be requested before the report due date.


Contact: (888) 925-4127

Louisiana holder resources

 

Notes from UPPO’s state administrator survey:

  • We have added a manual reporting option for holders to enter their data in lieu of uploading a NAUPA file. This feature is targeted to small holders who may not wish to purchase reporting software. We are phasing out paper reports. For 2018, we will continue to accept paper for less than 25 items, but this will be last year for paper reports.
  •  Louisiana no longer accepts HDE files. 
  • Louisiana no longer corrects incomplete data or incorrect codes in a holder’s NAUPA files. 
  • NAUPA files with errors will be rejected and must be corrected by the holder.

 

Maine

Report due: Nov. 1, 2018
Extensions: Extensions may be requested before the report due date.


Contact: up.holderinquiry@maine.gov or (207) 624-7470

Maine holder resources

 

Maryland

Report due: Oct. 31, 2018
Extensions: Extensions may be requested by mail or email before the report due date.


Contact: upholder@comp.state.md.us or (410) 767-1700 or (800) 782-7383

Maryland holder resources

 

Notes from UPPO’s state administrator survey:

  • Always use our web portal and send confirmation of payment instructions.

 

Massachusetts

Report due: Nov. 1, 2018
Extensions: Extensions may be requested.


Contact: UCPReporting@tre.state.ma.us or (617) 367-0400

Massachusetts holder resources

 

Minnesota

Report due: Nov. 1, 2018
Extensions: Extensions may be requested at least 30 days before the reporting due date. 


Contact: holder.unclaimed@state.mn.us or (651) 539-1545

Minnesota 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:  fall reporting  unclaimed property 

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2018 Fall Reporting Guide Part 1 (Alabama – Hawaii)

Posted By Administration, Thursday, July 19, 2018

Fall reporting season is again fast approaching. Most U.S. states require holders to file reports by either Oct. 31 or Nov. 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. Because of the amount of information included, this guide will be published in four parts over the next two weeks:

 

Part 1 covers Alabama through Hawaii.

Part 2 covers Idaho through Minnesota

Part 3 covers Mississippi through Rhode Island.

Part 4 covers South Carolina through Wyoming.

 

Alabama

Report due: Nov. 1, 2018
Extensions: Extensions may be requested.


Contact: unclaimed@treasury.alabama.gov or (334) 242-9614 or (888) 844-8400
Alabama holder resources 


Alaska

Report due: Oct. 31, 2018
Extensions: Extensions may be requested by mail or fax. Include reason for extension request and length of extension needed.


Contact: ucproperty@alaska.gov or (907) 465-3726
Alaska holder resources 


Arizona

Report due: Oct. 31, 2018
Extensions: Extensions may be requested by fax or email. Include company name, holder number or company FEIN, reason for extension request and length of extension needed. 


Contact: ReportingUnclaimedProperty@azdor.gov or (602) 716-6031
Arizona holder resources 


Arkansas

Report due: Oct. 31, 2018
Extensions: Extensions may be requested.


Contact: holders@auditor.ar.gov or (501) 682-6000 
Arkansas holder resources 

 

Notes from UPPO’s state administrator survey:

  • Instruction manual/handbook has been updated in the past three months.
  • Online reporting is required.
  • Due diligence threshold change: Act 622 amended periods for providing notice. The effective date of the Act is 8/1/2017. As such, holders will be expected to comply on 2018 filings.
  • Notice timing change: Act 622 amended periods for providing notice. The effective date of the Act is 8/1/2017. As such, holders will be expected to comply on 2018 filings.
  • Due diligence method change: Securities and sdb's must be sent by letter.
  • Report file type change: Arkansas requires all holder reports to be submitted electronically in a NAUPA-formatted file using certain options. Please refer to reporting booklet.
  • Some common areas of concern have been when holders submit a report without a payment or incorrect payment or when holders submit a payment without a report. We hope that by limiting the methods of reporting, holders may be able to more accurately reconcile their filings.


California 

Report due: Oct. 31, 2018, for Holder Notice Reports
Extensions: Extensions may be requested no later than 30 days before the due date. 

Contact: updholderoutreach@sco.ca.gov or (916) 464-6088 
California holder resources

Colorado

Report due: Nov. 1, 2018
Extensions: Extensions may be requested before the due date. Include company name, reason for extension request and length of extension needed. 


Contact: Holders@state.co.us or (303) 866-6070 or (800) 825-2111
Colorado holder resources 

 

Notes from UPPO’s state administrator survey:

  • You don’t need to mail in disks anymore. Colorado allows businesses to file their unclaimed property reports directly to us through our online portal.
  • ACH instructions are now at https://colorado.findyourunclaimedproperty.com/app/remitting-guidelines.
  • We also have a separate email for holder questions, Holders@state.co.us.
  • Checks are still accepted but please write the EIN on the front of the check in order to facilitate matching with reports.
  • Report file type change: Colorado no longer accepts reports with HDE encryption. Your NAUPA file may be in .txt, .hrs or .rpt format. Paper reports will no longer be accepted.

District of Columbia

Report due: Oct. 31, 2018
Extensions: Extensions may be requested before the due date. Include reason for extension request. 


Contact: DCUnclaimed.Property@dc.gov or (202) 442-8181
District of Columbia holder resources 

 

Georgia

Report due: Nov. 1, 2018
Extensions: No details provided


Contact: ucpmail@dor.ga.gov or (855) 329-9863
Georgia holder resources 

 

Notes from UPPO’s state administrator survey:

  • Instruction manual/handbook has been updated in the past three months.


Hawaii

Report due: Nov. 1, 2018
Extensions: Extensions may be requested by mail on company letterhead. Approvals will extend the reporting deadline until Jan. 1. 


Contact: Varies by island
Hawaii 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:  fall reporting  unclaimed property 

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