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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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Appeals Court Sides with Federal Government Over States in Unclaimed Savings Bond Battle

Posted By Administration, Thursday, August 15, 2019

On Aug. 13, 2019, the U.S. Court of Appeals for the Federal Circuit ruled in favor of the U.S. Treasury in a dispute with Kansas and Arkansas over the handling of unclaimed savings bonds. 

 

The states sought to enforce escheat laws specifying that, if bond owners fail to redeem their savings bonds within five years after maturity, the bonds would be considered abandoned and would transfer to the states two or three years later. When the U.S. Treasury refused the states’ efforts to claim such bonds, the states filed suit. A U.S. Claims Court sided with Kansas and Arkansas, and the federal government appealed.

 

In its reversal, the Appeals Court provided two reasons for ruling in favor of the U.S. Treasury:

  1. Federal law preempts state escheat laws, meaning the bonds belong to the original bond owners rather than the states.
  2. Even if the states owned the bonds, they were not entitled to rights greater than the original bond owners, who must provide the serial number to redeem bonds six years or more past maturity. Because the states don’t have the physical bonds or serial numbers, the Treasury acted properly when denying their redemption request.

Despite the loss, states continue to pursue the estimated $25 billion in unclaimed savings bond funds. On Aug. 1, 2019, Sen. John N. Kennedy (R-Louisiana) introduced S. 2417, the Unclaimed Savings Bond Act of 2019. If passed and signed into law, the bill would give states access to information about unclaimed savings bonds for inclusion in unclaimed property databases and, ultimately, the ability to claim and redeem the bonds. 

 

Before serving in the U.S. Senate, Kennedy was state treasurer in Louisiana. His bill currently has two cosponsors, Sen. Jerry Moran (R-Kansas) and Sen. Bill Cassidy (R-Louisiana). S. 2417 has been assigned to the Senate Finance Committee, where it awaits further action.

Tags:  Arkansas  Kansas  legislation  litigation  savings bonds  U.S. Treasury  unclaimed property 

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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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2019 Fall Reporting Guide Part 4 (South Carolina – Wyoming)

Posted By Administration, Thursday, August 1, 2019

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 covered Alabama through Hawaii.

Part 2 covered Idaho through Minnesota.

Part 3 covered Mississippi through Rhode Island.

Part 4 covers South Carolina through Wyoming.

 

South Carolina

Report due: Nov. 1, 2019
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

 

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:

  • Aggregate amount has been lowered to less than $10 beginning July 1, 2019. This does not affect the Nov. 1 reports since the period ending is June 30.
  • South Dakota has received several reports with gift cards that do not have actual card numbers on the property. Actual card numbers must be included.
  • South Dakota will have a new procedure for reporting savings bonds beginning with the Nov. 1, 2020, reporting deadline. Instructions will be coming out in the holders manual and the website.

 

Tennessee

Report due: Nov. 1, 2019

Extensions: Extensions may be requested.

 

Contact: ucp.holders@tn.gov or (615) 253-5362

Tennessee holder resources

 

Utah

Report due: Nov. 1, 2019
Extensions: Extensions may be requested in writing before the report due date.

 

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

Utah holder resources

 

Notes from UPPO’s state administrator survey:

  • Instruction manual/handbook has been updated in the past three months.
  • Utah encourages the use of the online payment process at the time of filing the online reports.  The reliability of the online payment process is much improved from the past couple of years where reporters were unsure that the online payment process worked correctly.   

 

Virgin Islands

Report due: Oct. 31, 2019
Extensions: No details provided.

 

Contact: (340) 774-2991, ext. 4 (St. Thomas) or (340) 773-6449, ext. 4 (St. Croix)

Virgin Islands holder resources

 

Virginia

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

 

Contact: William.Dadmun@trs.virginia.gov or (804) 225-2547 

Virginia holder resources

 

Notes from UPPO’s state administrator survey:

  • Instruction manual/handbook has been updated in the past three months.
  • New URL: www.vamoneysearch.org/report
  • When reporting co-owned accounts, there are certain combinations of Owner Relationship Codes that are not acceptable. This is discussed in Virginia’s Special Notices - New for 2019document on its website, along with other helpful hints. Please read this document.

 

Washington

Report due: Oct. 31, 2019
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

Washington holder resources

 

West Virginia

Report due: Oct. 31, 2019
Extensions: Extensions may be 
requested.

 

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

West Virginia holder resources

 

Notes from UPPO’s state administrator survey:

  • Key contact changes: The UP Director (Carolyn Atkinson) and Receipts Manager (Sara Withrow) have left the Treasurer’s Office. For reporting questions please contact Abigail Campbell, receipts manager at abigail.campbell@wvsto.com.
  • New Legislation - Linked Accounts (Banks only): HB 2609- Bank Accounts; Effective 6/2/2019  - New language in §36-8-2 allows for "linked accounts" in West Virginia - Checking accounts, savings accounts and CDs are linked; if one account is active, all accounts are considered active and not presumed abandoned (d) An indication of an owner's interest in property includes: (5) For demand, savings and time deposits held by a financial organization, any indication of the owner's interest in any demand, savings and time deposit held by the financial organization for that owner is an indication of the owner's interest in all demand, savings and time deposits held by that financial organization.  

 

Wisconsin

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

 

Contact: DORWIHolderReports@wisconsin.gov or (608) 264-4594

Wisconsin holder resources

 

Notes from UPPO’s state administrator survey:

  • Instruction manual/handbook has been updated in the past three months.
  • Step by step instructional videos have been added to Wisconsin’s unclaimed property website.
  • Wisconsin only accepts electronic filing in .txt format.
  • Complete owner & address information is appreciated to facilitate our automated data match process.
  • Frequent reporting error: Coding property as aggregate or unknown when the property owner is known, should be "All Other Owners" for the owner type, missing information on reports (parts of name or address).
  • All correspondence should be sent to PO Box 8982 Madison, WI 53708-8982 the old PO Box 2114 is no longer active and will return any items to sender.

 

Wyoming

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

 

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

Wyoming holder resources

 

Notes from UPPO’s state administrator survey:

  • New legislation that goes into effect July 1, 2019, requires holders of life insurance policies to select a box that says: "I hereby acknowledge that the following requirements have been met per W.S. 26-16-505(h): A. A beneficiary has not submitted a claim with the insurer; and B. The insurer has complied with W.S. 26-16-505 and has been unable, after good faith efforts documented by the insurer, to contact the beneficiary."
  • Wyoming hopes to be able to allow payments via EFT in this reporting season, but doesn't know for sure it that will be available.

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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2019 Fall Reporting Guide Part 3 (Mississippi – Rhode Island)

Posted By Administration, Thursday, July 25, 2019

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 covered Alabama through Hawaii.

Part 2 covered Idaho through Minnesota.

Part 3 covers Mississippi through Rhode Island.

Part 4 will cover South Carolina through Wyoming.

 

 

Mississippi

Report due: Nov. 1, 2019
Extensions: No details provided


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

Mississippi holder resources

 

Missouri

Report due: Nov. 1, 2019
Extensions: Extensions may be requested in writing at least 30 days before the reporting due date.


Contact: ucp@treasurer.mo.gov or (573) 751-0123

Missouri holder resources

 

Notes from UPPO’s state administrator survey:

  • Missouri recommends that any holder reporting more than 50 owners file electronically.

Montana

Report due: Nov. 1, 2019
Extensions: No details provided.


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

Montana holder resources

 

Notes from UPPO’s state administrator survey:

  • New online filing is now faster and more efficient. Use the TransAction Portal at https://tap.dor.mt.gov to upload your holder report and send payment.
  • New upload process and new payment option that don't require a login.
  • Instruction manual/handbook has been updated in the past three months.

Nebraska

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


Contact: 
Email form

Nebraska holder resources

 

Nevada

Report due: Oct. 31, 2019
Extensions: Extensions may be 
requested.


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

Nevada holder resources

 

Notes from UPPO’s state administrator survey:

  • Holder manual/handbook is expected to be updated before the next reporting deadline.
  • Reminder: Submitting reports online is mandatory.
  • Written authorization from Nevada’s unclaimed property office is required to file other than by online.
  • Payment by ACH debit is mandatory. With the exception of government entities, ACH credit, wire transfers and check are no longer accepted. An ACH Debit Exception Request must be completed to pay by other means.
  • When the report is uploaded, payment by ACH debit must occur simultaneously through the online portal unless payment to pay otherwise has been authorized by Nevada’s unclaimed property office.
  • Holders will be updated with legislative changes by email and Nevada’s unclaimed property website in the near future.
  • Common reporting error: Misclassifying “payroll” as uncashed checks and high instances of this these properties being reported with multiple owners and relationship codes other than SO.
  • Please review SB 44 for changes, effective July 1, 2019. Industry notices will be published in the near future, giving more guidance with timing of implementation. Sign up for Holder notifications is available at nevadatreasurer.gov (on the holder information page) as well as on the reporting portal.  

New Hampshire

Report due: Nov. 1, 2019
Extensions: No details provided


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

New Hampshire holder resources

 

Notes from UPPO’s state administrator survey:

  • Holder manual/handbook is expected to be updated before the next reporting deadline.
  • New electronic upload features from our website. CDs, Floppy Disk or any other storage media will not be accepted after 7/1/2019.
  • Common reporting errors: Early/late reporting because holders do not understand fiscal period reporting. Incomplete information and incorrect formatting of data are also a common problem.
  • Payment is expected at time of filing.

New Jersey

Report due: Oct. 31, 2019
Extensions: Extensions may be 
requested.


Contact: unclaimedreports@treas.nj.gov or (609) 292-9200

New Jersey holder resources

 

New Mexico

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


Contact: Email form or (505) 827-0762 

New Mexico holder resources

 

North Carolina

Report due: Nov. 1, 2019
Extensions: Extensions may be 
requested by Oct. 1.


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

North Carolina holder resources

 

Notes from UPPO’s state administrator survey:

  • Holder manual/handbook is expected to be updated before the next reporting deadline.
  • Significant changes to online reporting will be taking place late July. Information will be communicated to holders soon.

North Dakota

Report due: Nov. 1, 2019
Extensions: Extensions may be requested in writing.


Contact: unclaimed@nd.gov or (701) 328-2800

North Dakota holder resources

 

Notes from UPPO’s state administrator survey:

  • New website: https://unclaimedproperty.nd.gov
  • Holder manual/handbook has been updated in the last three months.
  • Electronic reporting required for 2019. Portal added to upload reports directly.
  • ACH payment option on the website is now the preferred method of payment.

Ohio

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


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

Ohio holder resources

 

Notes from UPPO’s state administrator survey:

  • Holder manual/handbook has been updated in the last three months.
  • More forms are now accessible online.
  • Extensions to file the current reporting year is from July 1 to November 1 for non-Life Insurance Companies. Extensions to file the current reporting year for Life Insurance Companies can only be filed online from January 1 to May 1.

Oklahoma

Report due: Oct. 31, 2019
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

 

Notes from UPPO’s state administrator survey:

  • Oklahoma does not accept EFT payments at this time. Remittance via check is required when file is submitted.
  • New address for remittance submission: Oklahoma State Treasurer Unclaimed Property, 9520 N. May Ave., LL, Oklahoma City, OK 73120

Oregon

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

 

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

Oregon holder resources

 

Notes from UPPO’s state administrator survey:

  • Holder manual/handbook is expected to be updated before the next reporting deadline.
  • Oregon will be changing computer systems to Kelmar's KAPS reporting system for fall reporting, allowing both uploading of data files as well as manual reporting.
  • Oregon will no longer accept .HDE formatted files. 
  • Oregon’s state administrator has changed to Claudia Ciobanu as the new trust property administrator.

Rhode Island

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

 

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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2019 Fall Reporting Guide Part 2 (Idaho – Minnesota)

Posted By Administration, Tuesday, July 23, 2019
Updated: Monday, July 22, 2019

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 covered Alabama through Hawaii.

Part 2 covers Idaho through Minnesota.

Part 3 will cover Mississippi through Rhode Island.

Part 4 will cover South Carolina through Wyoming.

 


Idaho

Report due: Nov. 1, 2019
Extensions: Extensions may be 
requestedbefore the report due date. 


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

 

Indiana

Report due: Nov. 1, 2019
Extensions: Extensions may be 
requested at least 30 days before the reporting due date.


Contact: 
updholder@atg.in.gov, (317) 234-9768
Indiana holder resources

 

Iowa

Report due: Nov. 1, 2019
Extensions: Extensions may be 
requested  before the reporting due date.


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

 

Kansas

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


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

 

Notes from UPPO’s state administrator survey:

  • You can no longer log into the Kansas system for reporting. NAUPA files can still be uploaded without needing an account.

 

Kentucky

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


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

Kentucky holder resources

 

Louisiana

Report due: Oct. 31, 2019
Extensions: Extensions may be requested before the report due date.


Contact: (888) 925-4127

Louisiana holder resources

 

Notes from UPPO’s state administrator survey:

  • Louisiana no longer accepts paper reports regardless of size. 
  • NAUPA standard files are required, uploaded to the state’s unclaimed property website is preferred method of delivery.
  • Banks only: Louisiana statute now provides for the presumption of abandonment and transfer to the state’s unclaimed property office of military medals and accompanying documents from safe deposit boxes.

 

Maine

Report due: Nov. 1, 2019
Extensions: Extensions may be 
requested before the report due date.


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

Maine holder resources

 

Notes from UPPO’s state administrator survey:

  • Holder manual/handbook updated in last three months.
  • Manual enter reports and file uploads. Emailed files are no longer accepted.
  • Maine cannot receive encrypted or password protected files.
  • There has been an increase in holders submitting the HRSPro and ETM templates instead of the NAUPA files that are required. Owner information needs to be provided according to statute. Title 33 Section 1958.
  • Payments can be made to the PayMaine portal at https://paymaine-prod1.pegacloud.net/or by check. Maine is no longer receiving payments by ACH Credit to the US Bank account.

 

Maryland

Report due: Oct. 31, 2019
Extensions: Extensions may be requested.


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

Maryland holder resources

 

Notes from UPPO’s state administrator survey:

  • Maryland’s depository bank account is being changed due to state contracting. Manual will be updated once that change is in effect, which is expected this summer.
  • Depository account will be changing from Bank of America to Wells Fargo. This will affect direct debits/ACHs. At this time, account is still with BOA. The transition is expected to be complete prior to the October reporting season.

 

Massachusetts

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


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

Massachusetts holder resources

 

Minnesota

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


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

Minnesota holder resources

 

Notes from UPPO’s state administrator survey:

  • Holder manual/handbook updated in last three months.
  • Claim property directly from the Minnesota website. Functionality allows for multiple properties to be added to one claim.
  • Rate for interest bearing account information is often in the incorrect format. Holders sometimes do not realize that we need last known address even if the information has proven to no longer be valid.
  • Payment due at time of filing.
  • Minnesota no longer accepts paper reports.

 

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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