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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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Considering and Evaluating Third-Party Administrators

Posted By Administration, Thursday, July 16, 2020

Third-party administrators provide useful services to businesses who may not have the capabilities or desire to handle their own unclaimed property responsibilities. TPAs provide a broad variety of services, including:

  • Compliance services, such as assisting with policies and procedures and preparing holder reports.
  • Reporting services, including due diligence and record keeping, full-service reporting for all property types, or reporting for select property types.
  • Accounting services, such as issuing checks and administration of voided and reissued checks.
  • Audit services, including assistance with unclaimed property audits or voluntary disclosure agreement programs.

Deciding whether to hire a third-party administrator begins with assessing your company’s current unclaimed property compliance capabilities. Consider the areas where you need the most help. Do you need assistance only with due diligence, or reporting as well? Do you need help with all property types or just a few? What budget is available? Does working with a third-party fit your company’s strategies and capabilities better than hiring one or more employees to fill the same role?

 

When interviewing potential partners, ask important questions regarding the TPA’s services, such as:

  • Does the TPA track, implement and share legislative, regulatory and legal changes?
  • Will the TPA indemnify your company for late or erroneous reports?
  • What is the TPA’s experience with companies similar in size and in the same industry?
  • What is the TPA’s experience tracking dormancy triggers?
  • What is the TPA’s experience defending its reporting in an audit?
  • What relationship does the TPA have with state administrators?
  • How does the TPA keep your data secure and will it indemnify your company in the event of a breach?
  • What reports will the TPA provide to ensure standards are being met?
  • Does the TPA use address verification services in advance of due diligence outreach?
  • What is the fee structure and total annual cost?

When evaluating whether working with a TPA makes sense, it’s especially important to understand that hiring a TPA does not absolve a company of its reporting responsibilities. Even with contracts requiring the TPA to handle unclaimed property, states still consider the company the unclaimed property holder. Responsibility ultimately falls on the unclaimed property holder.

 

If the TPA fails to fulfill the obligation, states will hold the holder accountable to fulfill outstanding obligations. As such, setting clear expectations when contracting with a TPA is essential at the outset. Identify who owns reporting-related functions internally and externally and ensure roles and responsibilities are clearly defined in the contract.

 

Because many companies have limited internal resources for unclaimed property management, third-party administrators play a vital role in the compliance process. Taking proactive steps during the evaluation process helps ensure a positive, long-term relationship between the holder and TPA.

 

To learn about UPPO members offering TPA services, visit our Service Provider & Vendor Directory. 

Tags:  servi  third party administrators  TPAs  unclaimed property 

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Practical Insights and Deeper Dives Highlight Annual Conference Sessions

Posted By Administration, Wednesday, January 9, 2019

 

 

Unclaimed property continues to provide a maze of compliance challenges for the professionals charged with managing their companies’ escheatment responsibilities. This year’s UPPO Annual Conference agenda offers a wide variety of sessions designed to help navigate that maze and keep up with the latest trends.

 

Managing Relationships

If your company is using third-party agents for employee benefits, payroll, equity or other services, understanding the roles of each party and ensuring everyone is properly fulfilling their responsibilities is essential to the unclaimed property reporting process. The Managing Your Third-Party Administrator session will offer tips for managing this important relationship.

 

The Bridging the Gap session looks at another key relationship – the one between holders and the states. This session will help attendees gain insight into building positive relationships with state administrators and maintaining a compliance program that is mutually beneficial to the holder, the state and property owners.

 

Emerging Property and Account Types

Unclaimed property compliance involves much more than uncashed payroll checks and customer credits. Dive into the specific requirements and considerations for unique account types in the unclaimed property process during the Unique Accounts with Unique Requirements session. Attendees with explore developments related to traditional and nontraditional retirement/IRA accounts, beneficiary accounts, HSAs and FSAs, and the effects of linking activity between customer accounts. 

 

Another rapidly evolving area of unclaimed property compliance is the world of virtual currencies. The Virtual Reality, Real Unclaimed Property session will look at issues arising from virtual currencies, blockchain technologies and modern incentive programs. Attendees will get insight into regulatory changes and practical considerations related to cryptocurrencies, virtual wallets and customer loyalty programs. 

 

Audits and VDAs

Always hot topics, unclaimed property audits and voluntary disclosure agreements will take center stage in several sessions. 

 

Unclaimed property professionals who haven’t yet been fully exposed to the audit process can gain an understanding of the concepts, timelines and expectations at the Audit 101 session. This introduction to audits will explore the scope and methodologies used by states and their third-party auditors. 

 

Holders under examination or participating in a VDA may be subject to estimated liability. The Estimation Under Audits and VDAs session will explore estimation methodologies and considerations and examine how states differ in their estimation practices. 

 

With so many companies incorporated in Delaware, that state spends a lot of time in the unclaimed property spotlight, but other states can’t be neglected. The Non-Delaware Voluntary Compliance session will look at VDAs in other states and when an informal approach may be more beneficial than a formal VDA. 

 

Not all third-party auditors were created alike. In fact, their processes and procedures vary greatly. The Third-Party Auditor Differences session will walk through the many different document requests that holders can expect throughout the audit process and will examine conflicting auditor requests when under audit by multiple states using different firms. 

 

View complete details about educational sessions and other 2019 UPPO Annual Conference events. The early-bird registration deadline is Jan. 28, so register today for the best rate.

 

 

 

 

 

Tags:  audits  cryptocurrency  IRAs  state administrators  TPAs  UPPO Annual Conference  VDAs  virtual currency 

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