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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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Insights from the NAST Symposium, Part 3

Posted By By Christa DeOliveira and Michael Unger, Thursday, August 8, 2019

The National Association of State Treasurers’ (NAST) Annual Treasury Management Training Symposium held during May 2019 in Providence, Rhode Island, was engaging and enlightening. The National Association of Unclaimed Property Administrators (NAUPA) is affiliated with NAST and led the well-attended unclaimed property track of educational workshops and sessions. This blog post is part three in a series about the topics discussed in the symposium sessions. Read part one hereRead part two here.

 

Securities

Securities have a unique set of challenges, including sometimes complex transfer steps; various corporate actions, such as dividends being declared and stock splits; and fluctuating values. During the the conference session about securities, the demands of securities maintenance were a central topic. 

 

Speakers discussed the pros and cons of immediately liquidating securities. Pros include: 

  • Requires less portfolio maintenance, including tracking and addressing corporate actions/dividends. 
  • No need to reregister shares, eliminating the associated costs and any confusion with claimants.
  • No perception of market play, if schedule is set up correctly with custodian, as it removes state staff from the liquidation process.
  • Lower custodial costs. 

Cons include: 

  • Claimant complaints regarding liquidated shares.
  • Fluctuating security prices.
  • Holder needs to make holder claims, such as needing to claim back property if there was a reporting error.

 

Speakers stressed that, even when immediate or early liquidation is pursued, states will still require a securities staff. There remains a need to publish shares on the website or liquidate before properties go on website, and conduct outreach to owners with shares – all under stringent policies and procedures. The session also included a discussion of holders liquidating securities before reporting. Because SEC regulations prohibit holders from liquidating securities in the name of the owner, this is a controversial topic for holders. 

 

While a very small portion of securities, worthless securities come with unique challenges, which were addressed during the session. Not all states accept worthless securities, but some do. Some states sell their worthless securities to Raymond James for $0.01 per position, and after one year any that have not returned to value are written off. At the time of the conference, 31 states engage in this service.

 

Finally, this session discussed that not all states update their owner/property records to reflect corporate actions. Rather, some states wait until there is a claim and then pay claims based off the original reported shares and any effects of corporate actions according to the state’s custodian’s records. 

 

Cryptocurrency

Like the 2018 symposium, there was considerable interest in cryptocurrencies at this year’s event. A session was dedicated to education on blockchain as a decentralized, digital ledger and blockchain transactions. There were comparisons made between longstanding markets and exchanges and crypto exchanges, citing both similarities and the differences. Similarly, there were parallels drawn to reporting, receiving and maintaining stock and how cryptocurrency could work. There was also some discussion of who are holders and not holders in the crypto context. 

 

There are distinct differences with cryptocurrency when compared to traditional markets. One such difference is that, in traditional markets, different entities fulfill the roles of broker, exchange, clearing house and custodian. Whereas, with cryptocurrency one company can fulfill all of these roles. Also, there is not a single DTCC number or single receiving account to transfer various currencies for custody and subsequent maintenance. Therefore, a state’s delivery instructions could be rather complicated. 

 

To transfer, holders need a receiving address, which can be an alphanumeric string or a QR code representing the string. Each currency has its own specific address format, which are different lengths. For example, a Bitcoin address is 42 characters and a Litecoin address is 34 characters. Additionally, while state unclaimed property systems support decimal places for shares, cryptocurrencies need to have more decimal places to properly report and remit.

 

There remain many unanswered questions or unresolved processes related to this property type. For example, in the current NAUPA reporting format, there are not fields able to accept the necessary information for reporting. What if property was received from an unknown party and there is not an ability to reconcile it, or duplicate remittances occurred? How could this be identified? Would property be returned? 

 

Other possible hurdles encompass whether states or NAUPA should endorse specific exchanges. What should states do to restore an owner’s property? For example, if a holder had to swap currencies to be able to report it to a state, does the state need to switch it back to the original to satisfy the claim? How would states handle safe deposit box contents that include a paper or hardware wallet? How would this be safeguarded? Would it be converted to cash or kept in its original state? How would states detect and thwart fraudulent claims?

 

No exchange deals with all of the more than 2,500 different cryptocurrencies. How would states handle reporting and remitting of any cryptocurrencies that a state does not or cannot hold? Should states have holders convert to a main currency before remitting or perhaps convert to U.S. dollars? States could have as many wallets as needed to cover all currencies, but would they pursue this? States could even have holders not report and remit this property or only over a certain value threshold? 

 

The educational workshops and sessions at the unclaimed property track of the recent NAST Symposium covered important insights on securities and cryptocurrency topics. While the topics covered may not directly or indirectly impact all property type holders, it is worthwhile to remain aware of NAUPA developments. It is also important to be informed of opportunities to work together with states, where our expertise and needs are aligned, and we can share our respective unique expertise and insights, and related unclaimed property challenges or issues.  

 

More information on this symposium will be available in a future blog post.

 

Christa DeOliveira is chief compliance officer with Linking Assets Inc. Michael Unger is a senior manager with Crowe LLP’s unclaimed property practice. 

Tags:  cryptocurrency  NAST  NAUPA  securities  Unclaimed Property 

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Insights from the NAST Symposium, Part 2

Posted By Contribution by Christa DeOliveira and Michael Unger, Thursday, July 11, 2019
Updated: Thursday, July 11, 2019

The National Association of State Treasurers’ (NAST) Annual Treasury Management Training Symposium held during May 2019 in Providence, Rhode Island, was engaging and enlightening. The National Association of Unclaimed Property Administrators (NAUPA) is affiliated with NAST and led the well-attended unclaimed property track of educational workshops and sessions. This blog post is part two in a series about the topics discussed in the symposium sessions. Read part one here.

 

Legislation 

Discussion about RUUPA-inspired legislation characterized it as not following a one-size-fits-all approach. Some jurisdictions, including Colorado, the District of Columbia and Vermont, have repealed their unclaimed property statutes and enacted new versions of RUUPA that have been largely modeled after the Uniform Law Commission’s version. Others, including Maine, South Carolina and Washington, introduced amended versions of RUUPA.

 

Still other states, including Minnesota, maintained their existing statute with expansive modifications incorporating RUUPA-like designs. These bills keep significant portions of current law, including examination of records, release and holder indemnifications, associated periods of limitation, and owner claims. They also add many amended RUUPA provisions. 

 

Another approach is to limited the scope of changes by keeping existing law and incorporating RUUPA-inspired provisions. Nevada took this approach, as most of the current law remains intact, but it proposes several dormancy periods like RUUPA, allows for electronic owner outreach under specified conditions, and makes some adjustments to included property types.

 

Direct payments to owners were dubbed as the ultimate outreach. This is where the state issues a payment to the owner in the absence of a claim. Naturally, states conducting this type of direct payment have certain criteria, such as comparing the address on reported property to the address on tax records (or other state/government databases), and the dollar value of the payment. Colorado enacted this option as part of its RUUPA bill and Florida has pending legislation related to state and local governments on specified small-value claims. California, District of Columbia, Maine and Vermont were also cited for considering similar pending bills.

 

South Dakota enacted a reduction in aggregate reporting from $50 down to $10. There was pending legislation to eliminate aggregate reporting altogether in Connecticut, Nebraska and Nevada.

 

Time limits on claims was a hot topic again at this year’s symposium. Georgia has enacted narrow “pure” escheat legislation to terminate an owner’s right to claim property for unclaimed excess proceeds from the sale of abandoned vehicles. Hawaii had two such bills that failed. S.B. 978 would have property with a value of less than $250 escheat to the state, if not claimed within five years. H.B. 1130 would have had property less than $100 automatically escheat to the state upon being reported and remitted. In both Hawaii bills, the owners’ property rights would be fully terminated.

 

Notably, participants expressed concern about enacting time limits on claims. It was described as bad policy and in contrast to the purpose of unclaimed property laws existing to protect the property rights of owners. The shift from the state assuming title, rather than a custodial role, may cause due process violations and be constitutionally problematic, according to the discussion. It was also noted GASB accounting rules already have provisions for setting up reserves for the amount expected to be claimed and taking the rest into income. Again this year, NAUPA discussed drafting a resolution about preserving owner rights to claim unclaimed property from states in perpetuity.

 

It was reported that, at the time of the symposium, DMF matching requirements exist in 33 states, in some form. Colorado, Kansas and Wyoming added this requirement since last year’s symposium, and there was pending legislation in California, D.C. and Massachusetts.

 

Litigation

Litigation was also discussed. Several cases related to disputes in holders producing records were noted: Texas v. ClubCorp Holdings Inc.Commonwealth, Treasury Department. v. PPL Corporation.Delaware, Department of Finance v. Univar Inc., and Univar Inc. v. Geisenberger. Current active cases discussed were: Faasse v. Coinbase Inc. as a cryptocurrency case; Weinbach v. Boeing Company as a case asserting wrongful escheat; and United Insurance Company of America v. Patronis, appealing a prior insurance ruling in Florida. 

 

Cases related to the treatment of class action proceeds were cited: McLeod v. Bank of America, N.A. and Rodriguez v. Danell Custom Harvesting, LLC, and Tennille et al. v. The Western Union Co. et al. Two qui tam (whistleblower) cases were touched on: Total Asset Recovery Services, LLC v. MetLife Inc. and Delaware ex rel. French v. Overstock.com Inc.         

 

More expansively, Kolton v. Frerichs and Goldberg v. Frerichs deal with not paying interest on claims. In Goldberg v. Frerichs, loss of the time value of money on property can be compensated for by giving owners the benefit of interim earnings. In Goldberg, the court cited an example of a rare coin being reported and remitted as unclaimed property. If the coin is sold, the owner loses out on the opportunity of appreciation. As such, it is insufficient to compensate the owner simply with the sale proceeds when the owner claims his property. Instead, upon claiming, the owner would be entitled to the earnings on the invested proceeds as the best substitute for the loss of appreciation. In the Goldberg case, the court made the caveat that low value properties may be treated differently and are most unlikely to be entitled to earn interest where the administrative cost exceeds the interest. In April 2019, the plaintiffs’ in Goldbergsought to renew a class certification; therefore, this litigation is ongoing.

 

Based on this case the following questions were raised in the session: Will this lead to other litigation? Will this ruling be constrained to the 7th Circuit? Will states change their unclaimed property statutes to proactively address questions about interest? If states do decide to determine what will qualify as the threshold for accounts where the interest exceeds the administrative costs to preserve the account? If new statutes on interest are enacted what proxy will be used to determine the time value of money?

 

Time Bars

Currently there is not uniformity amongst state laws regarding the period of time after which a state cannot enforce its unclaimed property law. Such time bars can encompass periods of limitation, statutes of limitation, periods of repose or lapsed periods of enforcement. 

 

The different approaches include a set number of years; the number of years contingent on filing or notice; a hybrid of both; a limitation based on years to be examined under audit; some other form of limitation; or no time bar limitation at all. Also, states enacting RUUPA have followed different approaches, including following RUUPA language, maintaining provisions in current law or following other approaches.

 

The various versions of the Uniform Law Commission’s Uniform Unclaimed Property Acts contain different time bars, with the 2016 version listing five years from the date of a report and 10 years if no report was filed. In the presentation, it was noted this approach was not required and, instead, this was promulgated as an accommodation to holders.

 

The session equated time bars to an all-encompassing reporting exemption. It was noted that time bars regularly do not receive the deliberation they merit when drafting or considering new unclaimed property legislation. Further, the importance of weighing public and private interests when setting a time bar was raised.

 

While NAUPA succeeded on many controversial issues, it did not prevail on the matter of time bars, according to the discussion. NAUPA recommendations to the Uniform Law Commission were discussed as being 10 years, generally, but 15 years for either nonreporting or underreporting. The caveat to this was that if the holder’s books and records showed acknowledged liabilities that are presumed unclaimed, even if they were reportable prior to the time bar, it would not qualify. NAUPA communicated to the ULC it strongly opposed the ULC time bar provision.

 

Panelists discussed with certainty that shorter and more absolute time bars will result in less property being collected. The following recommendations were made related to enacting or revising legislation: do not include a time bar, but rather address look backs administratively; if a time bar is included, follow the 1995 Act provisions or what NAUPA proposed to the ULC; at minimum, follow the 1981 Act of 10 years plus the corresponding dormancy period; and consider the lessons of matured, unpaid life insurance.

 

The NAST Symposium unclaimed property track included important insights on legislation, suggestions on drafting legislation, court cases and time bars. While the topics covered may not directly or indirectly impact all property type holders, it is worthwhile to remain aware of NAUPA developments. It is also important to be informed of opportunities to work together with states, where our expertise and needs are aligned, and we can share our respective unique expertise and insights, and related unclaimed property challenges or issues.  

 

More information on this symposium will be available in future blog posts.

 

Christa DeOliveira is chief compliance officer with Linking Assets Inc. Michael Unger is a senior manager with Crowe LLP’s unclaimed property practice. 

 

Tags:  legislation  litigation  NAST  NAUPA  time bars  unclaimed property 

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Insights from the NAST Symposium, Part 1

Posted By Contribution by Christa DeOliveira and Michael Unger, Wednesday, July 3, 2019
Updated: Tuesday, June 25, 2019

The National Association of State Treasurers’ (NAST) Annual Treasury Management Training Symposium held during May 2019 in Providence, Rhode Island, was engaging and enlightening. The National Association of Unclaimed Property Administrators (NAUPA) is affiliated with NAST and led the well-attended unclaimed property track of educational workshops and sessions. This blog post is part one in a series about the topics discussed in the symposium sessions.

 

NAUPA 3

Still under development, the NAUPA 3 format will use Extensible Markup Language (XML) to offer previously unavailable flexibility for the evolution of data fields/information reported and to accommodate state-specific requirements. NAUPA will create a standard suggested XML Schema Definition, with the understanding that states have different statutory, regulatory and administrative data reporting requirements. Therefore, states will modify the schema to fit specific reporting needs. While there will continue to be differences across states, having the state-specific schema will greatly assist transfer agents and other holders to appropriately program their systems and determine which data needs to incorporate into the report file. The schema will also provide a means for upfront data validation tools to be built. 

 

Although progress has slowed, the NAUPA 3 initiative has been both thoughtful and comprehensive. Originally anticipated for completion by the end of 2018, NAUPA 3’s introduction has been pushed back to the end of 2019. The format will likely be sent to NAUPA members for feedback on approximately August 1. Shortly thereafter, it will be shared with unclaimed property reporting software developers and the larger holder community. This will provide an opportunity for additional input and commentary. It remains to be seen how quickly state and holder systems can be programmed once the final format is determined.

 

After the new format is completed and presented to the holder community and software providers for feedback, there will be more necessary and time-consuming steps. Specific details on transitioning to NAUPA 3 on a state-by-state level, as well as the timeframe when old and new formats will be concurrently accepted, remain unknown. NAUPA anticipates encouraging states to accept both formats for about a year.

 

Strategic Plan

NAUPA’s 2018-22 strategic plan remains in effect. The association continues to make resolutions and policy position papers a goal. Previously, NAUPA determined a need for policy positions, and it plans to adopt official policy statements. On the short list is a paper backing the position that NAUPA does not support pure escheat where an owner’s rights are terminated. 

 

Combatting Fraud

States continue to share knowledge and best practices about processing claims and combatting fraud. Fraud detection and prevention methods include using identity verification and risk scoring tools to look for red flags. Such efforts may focus on specific email addresses, track IP addresses where claims originate and examine browser versions being used. 

 

Rapid completion of forms and use of all capital letters may raise red flags, as most claimants do not fill out forms quickly or use all caps. Analysis of online user habits continues to get smarter, but offenders are also getting more sophisticated. It is important that risk profiles and risk scoring continue to evolve.

 

What is an acceptable amount of fraud? Inserting enough friction in the unclaimed property claims process to stop all fraud could result in the costs outweighing the benefits. A tiered approach is advisable, such as under $50 and high dollar claims requiring different levels of scrutiny. With a layered approach, there is not a single solution. 

 

In practice, confirming the validity of uploaded documents is difficult. Sometimes employees lack sophistication on complex claims procedures, checklists and knowing when to ask for help. Claims processors can look for anything misplaced or unusual. Does the document exactly match itself? Are the fonts the same? Is it a copy of a website? Relying on more than one document provides more data points for substantiation and analysis. 

 

There can also be fraud in holder reporting. States rely on holders to report properly and to prevent fraud before property gets reported to states. For example, a holder paid with a fraudulent credit card and subsequently tried to file claims the next day. Such fraud can be prevented by waiting 10 days and ensuring full receipt of the payment remittance before making property available for claims via the state’s website.

 

To reduce the possibility of internal fraud, states can build processes, including segregation of duties, dual sign off, co-duties and steps to look for collusion. Rotating job functions, having clearly defined roles and verifying employees are performing only authorized duties also reduce risk.

 

Other Trends

Most states reported consistent year-over-year increase in property returned to claimants. 

 

More states are planning to transition to KAPS as their software system in part for online reporting features it offers for states and holders. Also, the KAPS system aids states in claims support, and some data validation tools assist streamlining.

 

Individual State Highlights

Highlights from the State of the States sessions included:

  • Wyoming raised awareness of its program to allow owners of property to donate property to charity instead of claiming property to have it returned.
  • Delaware reported that approximately 50% of holders invited to participate in the secretary of state’s VDA program have opted in.
  • The New Brunswick unclaimed property program establishment push is reportedly losing momentum. 
  • Kentucky announced it will be cleaning up RUUPA soon.
  • In addition to Washington assessing penalties, it will also be starting a self-audit program.
  • Illinois reports it is focusing on preneed funeral contracts.

 

The NAST Symposium unclaimed property track included important insights on priorities, trends and highlighted educational topics. While the topics covered may not directly or indirectly impact all property type holders, it is worthwhile to remain aware of NAUPA developments. It is also important to be informed of opportunities to work together with states, where our expertise and needs are aligned, and we can share our respective unique expertise and insights, and related unclaimed property challenges or issues. 

 

More information on this symposium will be available in future blog posts.

 

Christa DeOliveira is chief compliance officer with Linking Assets Inc. Michael Unger is a senior manager with Crowe LLP’s unclaimed property practice. 

Tags:  fraud  NAST  NAUPA  NAUPA 3  unclaimed property 

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The Derivative Rights Doctrine: A Primer

Posted By Administration, Thursday, November 5, 2015

When a state takes possession of unclaimed property, it does so as a custodian of that property, taking on the absentee owner’s role. The Derivative Rights Doctrine is the premise that the state’s rights are then equal to those of the owner. Acting on behalf of the owner, the state should have identical rights to the property that the owner would otherwise have.

 

Actions taken by the states regarding unclaimed property, however, often surpass what original property owners could do on their own. As a result, the Derivative Rights Doctrine has been a point of contention between the holder community and the states as the Uniform Law Commission (ULC) works on the Revised Uniform Unclaimed Property Act (RUUPA).

 

How does the Derivative Rights Doctrine apply to unclaimed property?

One of several areas where the Derivative Rights Doctrine applies is the use of gift cards. When a company issues a gift card, it has an obligation to provide goods or services to the bearer of the card. Someone possessing a $100 Target gift card is entitled to $100 worth of Target merchandise, for example. It does not, however, entitle the gift card owner to $100 in cash from Target. If that gift card is unused, and a state requires Target to escheat $100 in cash so it can return that cash to the owner, it exceeds the rights of the owner, who would not have the authority to claim that cash from Target directly.

 

“Target isn’t a bank,” says Ethan Millar, partner with Alston & Bird LLP and American Bar Association (ABA) advisor to the ULC Drafting Committee to Revise the Uniform Unclaimed Property Act (drafting committee). “It isn’t holding cash for the owner of the gift card. The money belongs to Target. It shouldn’t have to pay that money to the state as unclaimed property. By requiring that, the state interferes with the contractual arrangement between the owner and Target, and converts an obligation to provide merchandise into an obligation to pay money”

 

Similar examples where the Derivative Rights Doctrine applies are movie tickets, prepaid spa packages and prepaid personal training sessions—anything where someone pays money in advance for a service that isn’t rendered or a good that isn’t delivered. Typically, either contractual terms or a legal statute of limitations dictates how long an owner has the ability to claim the purchased goods or services. State unclaimed property laws, however, are increasingly overriding these terms.

 

“Unclaimed property laws in many states have adopted contractual anti-limitations provisions,” Millar says. “These provisions attempt to nullify contractual limitations, such as expiration dates, regardless of the circumstances. However, there are already consumer protection laws that govern the validity of contractual limitations provisions. Thus, if businesses are exploiting someone, consumer protection laws already provide protection. The unclaimed property laws ignore this and seek to eliminate contractual restrictions regardless of what was agreed to and regardless of what is legally permissible under the consumer protection laws, effectively overriding these other laws.”

 

A personal trainer may offer a promotional package of 10 prepaid sessions for $500 to be used within six months. If at the end of that time, the purchaser has used only seven sessions, both parties understand that the contractually agreed upon time period has run its course. Under the Derivative Rights Doctrine, the three unused sessions would not be considered unclaimed property. The obligation expired, so the owner is entitled to no compensation. If unclaimed property laws require the business to escheat the value of those unused sessions, it is overstepping the original contract and giving the owner something not covered under the agreement.

 

The Derivative Rights Doctrine also applies when considering which party has the legal burden of proving a debt exists. Debtor/creditor laws say the burden of proof falls on the creditor—in the case of unclaimed property, the owner. Under the Derivative Rights Doctrine, the states should also have the burden when acting on behalf of unclaimed property owners. However, according to Millar, the states argue that the mere existence of a credit on a company’s accounting records shifts the burden to the holder to disprove that the credit represents unclaimed property. A creditor/owner doesn’t have the right to shift the burden of proof by simply pointing to the accounting records of a debtor/holder, so neither should the states under the concept of derivative rights.

 

Derivative Rights Doctrine in ULC drafting committee discussions

Though other holder groups, including UPPO, have supported the Derivative Rights Doctrine through written and verbal commentary to the drafting committee, the ABA is the leader in the push to include the Derivative Rights Doctrine in the RUUPA. In comments to the ULC, the ABA requests that the RUUPA incorporate the Derivative Rights Doctrine to ensure states truly represent unclaimed property owners but do not receive additional property rights.

 

“The purpose of the UUPA is simply to return unclaimed property to the rightful owner and not be used as a ‘back door’ to impose additional substantive regulations that may impact the debtor’s obligations to a creditor,” ABA writes.

 

NAUPA takes issue in its comments to the drafting committee with the premise that states’ rights should be identical to those of the unclaimed property owners they are representing. NAUPA also warns that making states’ unclaimed property rights equal to those of owners would spell the end of meaningful unclaimed property laws.

 

“Because a holder can easily invent some business purpose for any restriction on its obligation to the owners, surely all would do so,” NAUPA writes. “Any holder issuing a payment instrument or credit of any form—check, rebate, refund, traveler check, money order, stored value card, credit balance—would require that the instrument or credit be cashed or used within a time period fixed so that the holder can confiscate the funds.”

 

The ULC is seeking a balance between the opposing views, as gaining support from both sides is essential to the RUUPA’s adoption. Support from states and holders will likely play a significant factor in whether lawmakers ultimately embrace the revised act. Both have the ability to put pressure on lawmakers, so the ULC faces the difficult task of trying to draft an act that both sides will support and achieve the ultimate goal – uniformity.

 

The most recent RUUPA draft addresses the Derivative Rights Doctrine in its discussion of gift cards, but not other key issues, such as statutes of limitation, contractual limitations and burden of proof. The drafting committee continues to work on its next draft, which will likely be completed before its March 2016 meeting.

 

More Resources

Debrief of UPPO’s ULC Issues Refinement Submission

UPPO’s Advocacy page

 

Tags:  ABA  Derivative Rights Doctrine  NAUPA  reform  revised uniform unclaimed property act  RUUPA  ULC  unclaimed property  Uniform Law Commission 

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Insider’s View of the ULC Redraft Process

Posted By Administration, Thursday, August 7, 2014
Updated: Thursday, August 7, 2014

Curious what it’s like to be handily involved in the Uniform Law Commission’s (ULC) committee to revise the Uniform Unclaimed Property Act? Carolyn Atkinson, ULC advisor for the National Association of Unclaimed Property Administrators (NAUPA) and West Virginia deputy treasurer for unclaimed property will tell you during the Uniform Unclaimed Property Law Update session at the Holders Seminar – Atlanta, Sept. 17-18.

Twenty two individuals, representing a variety of organizations and stakeholder groups make up the ULC committee. Each individual has a slightly different role, ranging from co-chair to advisor. Advisors represent the interests of a stakeholder group identified as being critical to the revision process. NAUPA has two advisor seats. Atkinson fills one and NAUPA’s immediate past president Beth Pearce fills the second seat.

Atkinson says her role as a NAUPA advisor is to, “develop and solidify the ideas of NAUPA, seek feedback from the [NAUPA] members, attend meetings, research legal issues and coordinate state input.” During ULC meetings, Atkinson is solicited to provide NAUPA’s input on the issues and topics of discussion. 

Though the ULC is still in the beginning stage of the redrafting process, Atkinson comments that she is impressed by the “professionalism and even-handedness” of the ULC . The next step of the ULC is to review the comments submitted by the stakeholders.

If you are interested in learning more about the ULC, the drafting process, and the issue areas the organization will likely consider to redraft attend the Holders Seminar – Atlanta, Sept. 17-18. Atkinson will be co-presenting with UPPO Immediate Past President Karen Anderson.

Register for the Holder Seminar – Atlanta today!

More Resources
View the written comments submitted by UPPO
Join UPPO to ensure your views are represented in the reform process

 

Tags:  Carolyn Atkinson  NAUPA  reform  ULC  unclaimed property 

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