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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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A Look at the Trends Shaping 2016

Posted By Administration, Thursday, January 7, 2016

With 2015 already beginning to fade away in the rearview mirror, the start of the new year is the perfect time to scan the landscape and consider what may await on the road ahead. No question, 2016 is shaping up to be an action-packed year. Courts are considering several noteworthy unclaimed property cases. States continue to focus on unclaimed property issues. Holders find themselves subject to daunting audits. And the Uniform Law Commission (ULC) is scheduled to wrap up with its work on the Revised Uniform Unclaimed Property Act (RUUPA). With so many things happening, we asked several UPPO members to share their insights into the trends that may ultimately define 2016 for unclaimed property professionals.

 

Audits

Unclaimed property audits are changing on multiple fronts. For one, states are beginning to work with more audit firms. New names are joining familiar third-party auditors Kelmar and Verus, and this trend is likely to continue as Delaware has made a concerted effort to diversify. While holders certainly have no sentimental attachment to the familiar audit firms, the introduction of new players can be problematic. New auditors introduce new tactics and methodologies, diluting an already inconsistent process even further.

 

“For holders, the fact that there are new audit firms that aren’t as experienced in the unclaimed property audit process can cut both ways,” says Susan Han, principal of Ryan’s Abandoned and Unclaimed Property Practice. “The auditing and scoping process can be frustrating because these auditors are not as seasoned in unclaimed property and don’t always take into consideration the immateriality of certain acquisitions and property types.”

 

Similarly, additional states are expanding their audit efforts.

 

“As a result of their collaboration on the RUUPA, states are working closer than they have in the past,” says Michelle Andre, managing member of Tre Towers Advisory Group, and UPPO Government Relations and Advocacy Committee (GRAC) co-chair. “I think you’ll see more audits and they’ll broaden to not just the usual suspects like Delaware, New Jersey and Massachusetts.”

 

In fact, some companies are already finding themselves subject to multiple simultaneous multi-state audits from separate audit firms.

 

“I think we’ll see more holders subject to two or three separate audits at the same time—perhaps even two or three multi-state audits—conducted by different contract audit firms,” says Kendall Houghton, partner at Alston & Bird LLP and GRAC co-chair. “The ability to dedicate adequate resources to the audit response and defense function becomes a real problem when dealing with multiple audits at the same time.”

 

As this audit expansion grows, holders who historically have not been audit targets may find themselves in the crosshairs. With large companies in heavily targeted industries increasingly strengthening their compliance practices and limiting their exposure, auditors may branch out.

 

“Given that many Fortune 1000 companies already have unclaimed property processes in place or have undergone unclaimed property exams, new audits will likely target middle market revenue companies and industries that haven’t historically been explored for audits,” says Han.

 

Litigation

When it comes to audit practices, all eyes are on Temple-Inland Inc. v. Cook, a court case that questions Delaware’s use of and methodology for estimation in audits. Even with a decision likely this year, the ultimate impact may still be years away, assuming the losing party challenges the decision. Thus, additional litigation related to audits is likely.

 

“I think we’ll see more litigation involving audits, aimed at figuring out why companies got selected for audits and questioning how audits are conducted,” says Jamie Ryan, member with Bailey Cavalieri LLC. “I also think we’re going to see an increase in litigation because holders have become more educated. They know they have legal rights they can assert.”

 

Andre also sees more litigation aimed at defining the rights of states and their audit firms. “Companies are beginning to challenge whether the audit process entails illegal search and seizure,” she says. “The decisions for cases like Plains All American v. Cook will impact the way holders look at audits and how states conduct audits.”

 

Most recent unclaimed property litigation has been between holders and states, owners and holders, owners and states, or holders and auditors. However, like the seminal jurisdictional cases (Texas v. New Jersey, Pennsylvania v. New York and Delaware v. New York), more cases involving states battling each other could occur in the near future.

 

“Delaware law conflicts with the laws of many other states in regard to domicile of limited liability companies, so that could be an area of litigation—disputes between states,” says Chris Hopkins, partner with Crowe and Horwath LLP. “That could be very interesting to watch.”

 

Advocacy and legislation

Holders and states alike have been diligently working to promote their preferred revisions to the Revised Uniform Unclaimed Property Act (RUUPA). The ULC is expected to issue its final draft this summer, but that is by no means the end of the advocacy effort.

 

“Even though the ULC will promulgate a 2016 RUUPA in the summer, that just means it’s been adopted by the commissioners,” says Houghton. “There will need to be subsequent movement through state legislatures, so that act will be a significant focus through 2016 and beyond. It will likely take at least four to five years to see the full first wave of adoption.”

 

It’s anyone’s guess which aspects of the new act the states will ultimately adopt. Educating lawmakers and convincing them of the need for laws that are fair not only to the states themselves, but also the owners and holders will likely be difficult.

 

“It’s going to take a lot to get them to come around,” says Marcella Easly, senior compliance advisor at Unclaimed Property Consulting & Reporting LLC. “The state administrators are willing to work with the holders to change, but when the legislators get involved, it gets tough.”

 

As states prepare for the RUUPA, some may preemptively begin introducing legislation aimed at supporting their positions.

 

“The states may look to the recent 2015 drafts of the revised 1995 Uniform Unclaimed Property Act and begin introducing legislation to clarify their collective view of how unclaimed property compliance should be administered,” says Debbie L. Zumoff, chief compliance officer at Keane and chair of UPPO’s ULC workgroup. “We may see some early legislative proposals that would view securities, broker-dealer accounts and mutual funds, for example, via the catch-all provision of the laws, in an effort to reinforce an inactivity dormancy trigger for such asset classes. This would be a retreat from any notion of returned mail as a dormancy trigger for securities related assets and instead promote the notion of inactivity alone, increasing the potential for more assets to be presumed abandoned.”

 

States may also seek to limit their liability for the growth of property they liquidate.  

 

“We may see increased liability left at the threshold of the holder community,” Zumoff says. “States may propose legislation that will enhance the due diligence responsibilities of holders prior to reporting and limit state indemnification to the value of the property at the time it was delivered to the state. So if a holder delivers property to the state valued at $1,000 dollars and 10 years from now it’s worth $10,000, but the state sold it shortly after receiving same, the state might only indemnify the holder for the original $1,000 value, not the $9,000 growth. That sets up a catch-22 when it comes to owner claims for the property years after reporting. The states may not want to assume the liability for the growth.”

 

Karen Anderson, vice president, reporting compliance at Keane and GRAC co-chair, agrees that states and holders alike will likely ramp up their advocacy efforts before the new uniform act is issued.

 

“In spring 2016, some states may try to change their laws to indicate that the Derivative Rights Doctrine doesn’t apply to things like rebates or gift cards or business credits,” she says. “Also, businesses and their trade associations may push back by attempting to pass more business to business exemptions, because the ULC likely won't recommend a business exemption in the revised uniform law. So, business groups may advocate more intensely for those exemptions prior to the revised uniform act being adopted.”

 

Houghton also expects holders to continue seeking opportunities to fight for their legislative agenda in addition to defending against onerous state-backed legislation.

 

“I think holders will continue to identify opportunities to improve states’ unclaimed property laws and will promote legislation for that purpose,” she says. “In 2015, for example, the introduction of a B2B exemption in Nevada was a holder-introduced initiative. In Michigan, there was the recent enactment of laws to improve the audit process in the state. And, certainly, holders supported a Delaware law to render permanent the availability of the secretary of state’s VDA program. Holders are increasingly doing a better job of identifying specific areas to improve the landscape and fairness.”

 

Looking ahead

From landmark court decisions to the RUUPA final draft, 2016 is shaping up to be a significant year in the unclaimed property world. UPPO will continue to track and report on these and other developing trends throughout the year. Watch this blog for updates and attend UPPO educational events to help you adapt to the rapidly evolving unclaimed property environment.

 

Tags:  advocacy  audits  legislation  litigation  RUUPA  ULC  unclaimed property 

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We’re halfway through the ULC’s effort to revise the UUPA!

Posted By Administration, Thursday, July 30, 2015
Updated: Wednesday, July 29, 2015

We’re halfway through the Uniform Law Commission’s (ULC) effort to revise the Uniform Unclaimed Property Act! As we move into the next phase of the process, we want to share how the Revised Uniform Unclaimed Property Act (RUUPA) draft addresses UPPO’s top 5 advocacy issues, as determined by members through the advocacy survey conducted in summer 2013. UPPO work groups were formed around those priorities, to research and draft position statements on each issue.  Now, we want your input to identify the issues on which UPPO should continue to focus its advocacy efforts, before the RUUPA draft becomes final. Take the survey to share your thoughts.

Though we are only half-way, UPPO believes the current RUUPA draft reflects the ULC’s desire to produce a final product that infuses fairness, modernization, and clarity that is recognizable by all stakeholders. We understand there is still work to be done, and therefore will remain engaged through continued verbal and written commentary, attendance at relevant ULC meetings, and collaboration with other stakeholders.

Status of UPPO’s Top 5 advocacy issues


Priority 1: Due diligence timelines

To minimize the complexity facing holders, the RUUPA currently says* owner notification needs to be completed not less than 60 days before filing the report. This lends flexibility to holders to complete due diligence on their own timeline rather than be locked into a specific time period.  This timing was suggested by UPPO in its position statement which was initially drafted by one of UPPO’s work groups.


*To ensure Section 8(f) and (h)(2)(B) are consistent with Section 10 and what the ULC drafting committee agreed upon during the February 2015 meeting, the language regarding the due diligence timeframe needs to be altered to read “…not less than 60 days before filing a report”. UPPO believes this is a drafting oversight that will be corrected once it’s brought to the attention of the reporter. 

Priority 2: Record retention requirements

Section 21 of the RUUPA provides for a standard record retention period of 10 years, and lists the information required to be kept on file by the holder. The information holders must keep for 10 years is:

  • The date, place, and nature of the circumstances which give rise to the property right;
  • The amount or value of the property; and,
  • The last known address of the owner, if known to the holder. 

UPPO recommended the record retention requirement be seven years, and that holder records must be retrievable in case of an audit.

 


Priority 3: Electronic owner contact

One of UPPO’s primary messages and goals in its comments to the ULC was that the RUUPA needs to be modernized to include the technology that drives modern commercial transactions – including electronic owner contact and recurring ACH transactions. The RUUPA draft includes the following types of electronic owner contact:

  • Electronic communication by the owner to the holder or agent of the holder,
  • Electronic payment of a dividend, interest, or other distribution,

  • Owner-directed activity in the account (including accessing the account, increasing, decreasing, or change the amount in of property in the account) as acceptable forms of an owner’s interest in the property. 

Priority 4: Definition of owner contact

The current version of the RUUPA includes an expanded list of activities that are acceptable forms of owner contact, most of which were proposed by UPPO, but UPPO continues to advocate that the ULC drafting committee include automatic deposits and withdrawals as well.  Below is the list of activities that are included in the RUUPA as acceptable forms of contact:

  • Written communication (this includes electronic communication);

  • Oral communication (if the holder makes and preserves a record of the conversation);

  • Presentment of payment (check, electronic, or other instrument of payment) of a dividend, interest payment or other distribution;

  • Owner-directed activity in the account in which the property is held;

  • Making a deposit or withdrawal from an account in which the property is held*;

  • Payment of a premium with respect to an interest in an insurance policy;

  • Any action by an agent or other representative of an owner is presumed to have been done on behalf of the owner, and is considered an action by the owner.

*In addition, UPPO believes removing the brackets** placed around automatic withdrawals and deposits* in the current RUUPA draft (which means that this type of action may be excluded from the list of owner contact in the state adoption process) will better protect owners’ interests and align itself with how owners remain in touch with many of their property accounts.

 

**Brackets indicate that it’s an optional provision, and the adopting state can decide to include the provision in the adopted act.

 


Priority 5: Jurisdictional reporting deadlines

The RUUPA creates a standard reporting deadline for all non-life insurance holders of Nov. 1, and May 1 for insurance companies. 

 

As UPPO advocated, the RUUPA includes a provision which allows for elective early reporting by holders. The RUUPA specifically provides, if the holder has not succeeded in notifying the apparent owner of the property, the provision allows holders to voluntarily report and remit property that hasn’t yet been presumed abandoned. When the property is delivered to the state, the property will then be considered abandoned.

 

Questions about UPPO's advocacy strategy or how we are staying involved? Contact UPPO President Dana Terry.

 

More information

Register for this free, members-only webinar ULC Update Webinar, Aug. 18; 2 - 3 p.m. EST!

Tags:  advocacy  reform  RUUPA  unclaimed property  Uniform law commission  uniform unclaimed property act  UUPA 

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ULC meeting shows progress, but there’s more work to be done

Posted By Administration, Monday, March 30, 2015

The Uniform Law Commission (ULC) drafting committee to revise the Uniform Unclaimed Property Act (drafting committee) met in Washington D.C. Feb. 27 – 28 to discuss the latest version of the revised Uniform Unclaimed Property Act (RUUPA) draft.

UPPO left the meeting feeling that progress was made, but additional dialogue on critical issues broadly impacting the holder community such as the activities constituting contact, the definition of holder, and administrative appeals, need further clarity and consideration.

Issues impacting the securities industry are among those that require focused attention in the current RUUPA. Seeing the need for additional dialogue and compromise between stakeholders, the drafting committee co-chairs requested specific stakeholder groups to meet before the next drafting committee meeting to discuss various securities-related issues. Representatives from UPPO, the National Association of Unclaimed Property Administrators (NAUPA), and specific securities industry groups have been invited to attend this meeting, set to happen in mid-April. UPPO looks forward to the opportunity to converse directly with NAUPA and the drafting committee reporter on the intricacies and regulations of the securities industry that need to be considered in the RUUPA to ensure the final version is modernized, fair, and clear of ambiguities. 

Inclusions in the current RUUPA draft that positively impact holders:
Please note, that the RUUPA is not finalized and the content currently included or left out of the draft can change. 

Revised definition of address
The revised definition of address is two-fold. For the purpose of giving notice by mail to an apparent owner, the location of the apparent owner must be sufficient to direct the delivery of mail. For the purpose of determining first priority reporting jurisdiction of property held for an owner, the definition includes any description code, or indication of the location of the apparent owner, regardless of whether it is sufficient to direct the delivery of mail to the apparent owner.

Foreign address property
The draft includes a section that explicitly says it does not apply to property held, due, and owing to a person whose last known address is in a foreign country or to property arising out of a foreign transaction where the property is held in a foreign country or location.

Audits
Lack of audit regulations has been a serious issue for the holder community, and it’s positive to see the willingness of the drafting committee to codify guidelines that will prevent abuse and encourage transparency. New additions related to audits include:

  • The requirement of third-party audit contracts to be reviewed by the appropriate channels within a state government prior to awarding contracts.
  • A standard preventing state employees involved in unclaimed property to become employed by a third-party audit company for a specific amount of time following employment by a state government.
  • A requirement of the state unclaimed property program to provide annual audit results to state executive and legislative officials
  • Authorization for state governments to award contracts to third-party auditors which is based on a fixed fee, hourly fee, or contingent fee (if contingent fee contract is awarded, the state must define the percentage allowed)

The ULC reform process is a slow, deliberate process intended to give all stakeholders the opportunity to provide verbal and/or written feedback. The opportunity for UPPO to influence issues still exists and we will continue to represent the holder community by advocating for modernization, clarity, and fairness in the RUUPA.

If you have questions or comments regarding UPPO’s advocacy efforts contact UPPO Executive Director Toni Nuernberg.

Tags:  advocacy  revise  unclaimed property  Uniform Law Commission  Uniform Unclaimed Property Act 

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The ULC is meeting today. Do you know what they are discussing?

Posted By Administration, Friday, February 27, 2015

 

The Uniform Law Commission Committee to Revise the Uniform Unclaimed Property Act (drafting committee) will be meeting later this week, Feb. 27 – 28 in Washington D.C. The drafting committee will discuss the latest version of the revised Uniform Unclaimed Property Act (UUPA), and get one draft closer to finalization.

The drafting committee reporter has taken over 1,500 pages of written submissions to use as the basis of the 68 page UUPA draft. Some of the issues of particular interest to the holder community are described below:


Revised definition of address

The revised definition of address is two-fold. For the purpose of giving notice by mail to an apparent owner the location of the apparent owner sufficient to direct the delivery of mail. For the purpose of determining first priority jurisdiction of property held for an owner, includes any description code, or indication of the location of the apparent owner, regardless of whether it is sufficient to direct the delivery of mail to the apparent owner.

 

Activities that indicate interest by owner
An indication of an owner’s interest in property includes:

  • Any written communication, including electronic communication;
  • Any oral communication, if the holder makes and preserves record of communication;
  • Presentment of a check or other instrument of payment;
  • Owner-directed activity: including accessing the account, or direction by the owner to increase, decrease, or otherwise change the amount or type of property held in account;

  • Making a deposit or withdrawal from an account in which the property is held;

  • Payment of a premium with respect to a property interest in an insurance policy;

  • Any other action by the owner that demonstrates that the owner is aware that the property exists;

  • Any action by an agent or other representative of an owner, if done on behalf of the owner, is deemed an action by the owner.

Foreign address property

The draft includes a section that explicitly says it does not apply to property held, due, and owing to a person whose last known address is in a foreign country or to property arising out of a foreign transaction where the property is held in a foreign country or location.


Appealing an unjust, incorrect, or made in error determination
Holders would have the following options: 

  • Within 30 days of the administrator’s notice of determination of liability, a holder can request an informal conference with the administrator or an employee of the state. The informal conference will allow the holder to present its case to the administrator. Within 20 days of the conference, the administrator will issue the holder a decision. If a holder would like to challenge the conference decision they are able to bring suit in court.
  • As an alternative to filing suit against the determination, a holder wishing to challenge the administrator’s determination of liability would be able to proceed through an administrative appeals process.

Note: The reporter of the drafting committee favors the approach of the informal conference rather than administrative appeals process, which is clearly stated through this section of the draft. In UPPO’s written submission, UPPO recommend an independent administrative procedure of handling disputes of determined holder liability as a mechanism to balance interests of holders and state administrators.


Keep in mind nothing in the draft is final. This weekend’s meeting will help the reporter and drafting committee gather additional information and commentary to assist in crafting an improved version. To ensure the holder community and UPPO members are heard, UPPO has appointed government relations and advocacy committee Co-Chair Kendall Houghton and UPPO President Debbie Zumoff to serve as UPPO's spokespersons.


Following the drafting committee meeting, UPPO will provide updated information regarding the discussion and the expected next steps.


If you have questions, contact Toni Nuernberg, executive director at 763-253-4344 or
toni@uppo.org.

 

More Information

Tags:  advocacy  reform  ULC  unclaimed property  Uniform Unclaimed Property Act  UPPO 

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Looking back at 2014 through the unclaimed property scope

Posted By Administration, Tuesday, December 30, 2014

2014 was a mixed bag of wins, setbacks, and promising changes for the unclaimed property holder community. There was no forum exempt from unclaimed property change, but our attention this year was drawn to the courts and the reform front. Conversation heavily focused on the happenings of the Uniform Law Commission (ULC), Delaware, and the life insurance arena. Below is our list of notable events that impacted the unclaimed property profession in 2014.

If you are itching for more information, make sure to attend the 2015 UPPO Annual Conference, March 8 – 11; Orlando, Fla. Kendall Houghton, partner at Alston & Bird, and, Sonia Walwyn, vice president of unclaimed property at Duff & Phelps will take attendees through a comprehensive look at the developments seen in 2014 during the session A Retrospective: 2014 Case Law, Legislative, and Regulatory Review.

Temple-Inland Inc. v. Cook
During a Delaware unclaimed property audit, Kelmar concluded Temple-Inland, a Delaware packaging manufacturer, failed to report $147.30 in unclaimed property; but was ultimately responsible for paying $1.38 million. Temple-Inland filed suit against Delaware officials and Kelmar, saying the parties violated federal common law, the Full Faith and Credit Clause, Commerce Clause and Takings Clause of the U.S. Constitution, by application of statistical estimation methods to establish liability.

The suit is ongoing and no final verdict has been made. Read more about the complaint.

Highland Homes Ltd. v. Texas
The Texas Supreme Court ruled against Texas' use of the unclaimed property law in Highland Homes, Ltd. v. The State of Texas.

Predating the aforementioned case, Highland Homes was faced with a class action lawsuit in 2009, which ended in a settlement between Highland Homes and the plaintiffs. The settlement created a cy pres award (meaning “next best use”), which dictated that all funds owed to individuals of the class action lawsuit by Highland Homes that remained unclaimed would be donated to charity through the cy pres award. The State of Texas argued that those unclaimed funds should have instead been reported and remitted to the state under its unclaimed property law.

The majority explained that the state’s anti-limitation provision, which is designed to prevent private contractual agreements from interfering with state unclaimed property laws, does not apply to uncashed checks from class action settlements. The court went on to say that unclaimed property laws do not require the class action members to actually collect the property -- merely to claim it (through the class representative).

Thrivent Financial for Lutherans v. State of Florida, Department of Financial Services
Over the past year the life insurance industry has been in the spotlight within the unclaimed property profession. Thrivent Financial for Lutherans prevailed in Florida when the Florida First District Court of Appeals (court) reversed a declaratory statement issued by the Florida Department of Financial Services (DFS).

The DFS’ declaratory statement claimed Florida law obligated life insurance companies to report unclaimed life insurance policies based on a dormancy period triggered by the date of death of the insured, rather than by receipt of proof of death by the life insurance company, which was the standard asserted by Thrivent Financial for Lutherans. The court rejected the DFS’ interpretation of its unclaimed property law in the declaratory statement, calling it “clearly erroneous because it ignores the plain language of the statute.”  In addition, the court rejected the DFS’ claim that life insurers are required to search the Death Master File for proof of death.    

The court’s reversal brings clarity and a positive development to the life insurance industry.  It’s predicted 2015 will be another active year for change within the industry.

Delaware ex rel. French v. Card Compliant LLC
A qui tam action (this type of action can be made when a whistleblower exposes fraud against the government and can receive a portion of the recovery as his or her reward) was filed against Card Compliant and numerous retail, restaurant and other clients of Card Compliant, alleging fraud under Delaware’s False Claims Reporting Act. The suit was brought by a whistleblower (a former Card Compliant executive) who claims Card Compliant created a scheme to prevent its gift-card issuing clients from reporting unredeemed gift card balances to Delaware.

This suit is ongoing but it could have implications for companies issuing gift cards. The stakes are higher in false claims litigation because the amount of damages sought is three times what it would be under general unclaimed property laws.

Delaware Unclaimed Property Task Force
The Delaware Unclaimed Property Task Force (task force) established by DE Senate Concurrent Resolution 59 critically examined the current unclaimed property program, including and its use of contract auditors to find ways to make the process more balanced and fair for all participants.

In early December, the task force released a report which included broad recommendations they will suggest the General Assembly consider to develop new legislation to improve fairness.  “The recommendations express that Delaware is listening and open to changes improving compliance with and fairness of its unclaimed property programs. It’s promising to see these recommendations.  The holder community is anticipating positive change,” says Debbie L. Zumoff, UPPO president.

Read a comprehensive review of the recommendations made by the task force.

Uniform Law Commission Reform Efforts
Though technically the Uniform Law Commission (ULC) officially took up the issue of unclaimed property reform in 2013, we’ve seen the most developments in 2014. The ULC’s Committee to Revise the Uniform Unclaimed Property Act (drafting committee) compiled a list of over 76 issues that had been included in the 1,500 pages of submitted comments and held discussion on the issues during its November meeting.

It’s still too early to indicate how the ULC and the drafting committee will stand  on particular issues, but a positive sign for significant change is the sheer number of participants and interest in the reform effort  has garnered. The meeting drew a larger crowd of individuals than any other issue taken up by the ULC aside from the Uniform Commercial Code.  The next meeting of the drafting committee will be held Feb. 27-28, 2015 in Washington D.C.

For a synopsis of the discussion that occurred during the Nov. 7 – 8 meeting.

2014 has brought many developments, and we only expect to see more in 2015. It’s an exciting time in unclaimed property so  make sure to stay tuned and engaged in what’s happening, as it will impact your job, department, and company. To learn more about the changes in 2014 register for the 2015 UPPO Annual Conference, March 8 – 11.


More Resources
For a look at changes on the regulatory and legislative front check govWATCH

Take a look at the submissions UPPO has made on behalf of UPPO membership in 2014

Tags:  2014  advocacy  reform  unclaimed property  UPPO 

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