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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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2020 Spring Reporting Guide

Posted By Administration, Thursday, February 13, 2020

Spring reporting season is again upon us. Several states require holders to file reports between March 1 and July 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. 

 

Connecticut 
Report due: March 30, 2020
Extensions: Extensions may be 
requested.


Contact: Maria Greenslade: 
maria.greenslade@ct.gov or (860) 702-3125
Connecticut holder resources 

 

Notes from UPPO’s state administrator survey:

  • Holder instruction manual has been updated in the past three months.
  • Please send all Connecticut reports to our lockbox location – PO Box 150435, Hartford, CT  06115-0435.  This is not a post office box and can accept overnight or certified deliveries. The office’s new physical location as of Jan. 10, 2020, is: 165 Capitol Ave., Hartford, CT  06106. 


Delaware
Report due: March 1, 2020
Extensions: Extensions may be 
requested.


Contact: 
escheat.holderquestions@delaware.gov or (302) 577-8782
Delaware holder resources.

 

Notes from UPPO’s state administrator survey:

  • Holder instruction manual has been updated in the past three months.
  • All filings must be made via the website. No paper or disk filings accepted. Holders may upload a NAUPA II-compliant file (many properties), or for holders with only a few properties to report, Delaware offers a “Manual Online Reporting” feature, where each property may be entered individually.
  • If reporting on a consolidated basis, please provide list of legal entities and FEINs that are included in the report. If using a third-party administrator to file, please provide current holder contact information, including updated information in the NAUPA file. Please clarify whether filing as a bank, insurance company, or “other”/corporation, to allow tracking of timely filings.
  • Payment is due upon filing.
  • Delaware made significant changes to its unclaimed property statute in SB 13, enacted February 2017.


Florida 
Report due: April 30, 2020
Extensions: Extensions may be 
requested.


Contact: 
EReporting@MyFloridaCFO.com, (850) 413-5522
Florida holder resources.

 

Notes from UPPO’s state administrator survey:

  • New holders can create their own Unclaimed Property ID. 
  • Holders can use online template for cash, securities and stock accounts with no limit to the number of owners for free.
  • Online reports only.
  • Failure to report complete information is an ongoing issue. Be sure to provide a full name and address. Make sure your data is in the correct field on the report.


Illinois 
Report due: May 1, 2020
Extensions: Extensions may be 
requested.


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

 

Michigan

Report due: July 1, 2020

Extensions: Extensions may be requested by email.

 

Contact: TreasUPDReporting@michigan.gov or (517) 636-6940

Michigan holder resources.

 

Notes from UPPO’s state administrator survey:

  • Updated holder instruction manual expected in February 2020.
  • Holders can now report properties and remit payments electronically.
  • Michigan allows for aggregate reporting but encourages all holders to report detailed individual properties to avoid having claimants return to them to clarify which aggregate property their funds are in. As always, the state expects holders to provide as much identifying, verifying information as possible. Without all information, claimants sometimes are referred back to holders for verification purposes. 
  • Because CEPAS has changed its company ID, holders will need to update their information with a new number provided on the payment website. 
  • EFT at the time of filing is the state’s preferred payment option. Because not every holder wants to participate in ACH debit, they may send a check if needed.
  • Please address remittance submissions to “MI Dept of Treasury Unclaimed Property” for improved routing.
  • Michigan is participating in the “TW” (tax withheld) deduction code recommended by NAUPA. Michigan is also developing a new relationship type for “contingent beneficiary” for holders to use on insurance properties – the code has not been confirmed as yet (NAUPA does not endorse a code at all; Michigan is researching options). Information for holders has been clearly posted on the state’s website.

 

New York 
Report due: March 10, 2020
Extensions: Extensions may be 
requested. 

Contact:  
nysrpu@osc.ny.gov or (800) 221-9311
New York holder resources.

 

Notes from UPPO’s state administrator survey:

  • Holder instruction manual has been updated in the past three months.
  • Excel formatted reports can now be sent via secure file upload. A new template is available for securities remittance correspondence. Uploaded files will use an electronic VCL (New York's summary sheet). Use only the Excel template provided on the website
  • The Handbook for Reporters is getting a new look with a quick reference sheet in the front of each industry section, with some parts already completed.
  • When companies report using NY or NAUPA formats, they should use the property type code to correspond with the format chosen. Do not mix the code/format. Also, remember to use relationship codes for multiple owner accounts. Not only will it increase the likeliness that the state will pay claims correctly in the future, but it reduces the number of times the state needs to reach back to the reporting company for account title clarification.
  • EFT payment at the time of reporting is not required, but remittance and report details are expected at the same time.

 

Pennsylvania 
Report due: April 15, 2020
Extensions: Extensions may be 
requested.  

Contact: 
report@patreasury.gov or (800) 379-3999
Pennsylvania holder resources. 

Notes from UPPO’s state administrator survey:

 

Texas

Report due: July 1, 2020

Extensions: Does not accept extension requests.

 

Contact: up.holder@cpa.texas.gov or (800) 321-2274

Texas holder resources.

 

Notes from UPPO’s state administrator survey:

  • Holder instruction manual has been updated in the past three months.

 

Vermont 
Report due: May 1, 2020
Extensions: Extension requests may be submitted in writing to the Unclaimed Property Division of the State of Vermont Office of the Treasurer at least 30 days before the reporting deadline. Describe the circumstance(s) for the delay and indicate the anticipated report delivery date.


Contact: 
tre.upcompliance@vermont.gov or (802) 828-2407
Vermont 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:  spring reporting  unclaimed property 

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New Tennessee Administrative Rules go into Effect

Posted By Administration, Thursday, March 7, 2019

On March 4, 2019, new administrative rules regarding unclaimed property went into effect. The rules are the latest in a series of updates to the state’s unclaimed property laws and practices, which also include the passage of H.B. 420, the state’s version of the Revised Uniform Unclaimed Property Act, and H.B. 2278, which changed the state’s unclaimed property reporting date from May 1 to Nov. 1. 

 

Noteworthy sections of the rules for holders include:

 

Reporting

  • Electronic reporting is required.
  • Negative reports may be filed. 
  • Reported cashier’s checks must include the name and address of the payee and purchaser, if known.
  • When filing initial safe deposit box reports, property should continue to be held for an additional year before filing a final report and turning over the property to the state.

 

Property Delivery

  • Most property should be remitted electronically via ACH or other method approved by the treasurer. 

 

Securities

  • Remitted securities shall include all dividends, interest, warrants or other rights, or associated cash payable by check or electronically.
  • Holders shall remit securities in such a form that future earnings will be delivered in cash rather than an increase in the number of shares. 
  • Holders shall remit securities in a form that allows the treasurer to sell them. 

 

Examinations

  • Holders will receive a notice of examination at least 30 days before an examination begins.
  • An examination will begin with an entrance conference at which time the examiner will identify other states participating; a tentative timeline and duration; a description of responsibilities; the potential types of records subject to examination; the lookback period; and an explanation of methods and estimation techniques that may be used.
  • An examination may include records of current accounts, dormant accounts and accounts that may have been closed and archived; agreements regarding the deduction of service charges; increases or decreases in account value; and interest payments; and policies and procedures.
  • If records are unavailable, estimation of liability may be used. The examiner will provide written notice of the estimation methodology and for which years. The examination subject may object to the estimation methodology by following the process defined by state law. 

 

Due Diligence

  • Holders are expected to conduct due diligence.
  • The return of first-class or superior mailing sent to the owner’s last-known address is considered evidence that the owner’s location cannot be ascertained. 
  • First-class or superior mailings that are not returned as “undeliverable” are considered owner contact and an indication of interest in the property. Examples include computerized account  or interest earning statements. 

 

Holders with unclaimed property reportable to Tennessee can access the new rules, related Tennessee laws and regulations, and additional compliance information on the state’s Treasury Department website.  

Tags:  audits  due diligence  examinations  reporting  securities  spring reporting  Tennessee 

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2019 Spring Reporting Guide

Posted By Administration, Wednesday, February 20, 2019

Spring reporting season is again upon us. Several states require holders to file reports between March 1 and July 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. 

 

Note: Tennessee was previously a spring reporting state but has since moved its filing date to fall. Details

 

Connecticut 
Report due: March 29, 2019
Extensions: Extensions may be requested.


Contact: Maria Greenslade: maria.greenslade@ct.gov or (860) 702-3125
Connecticut holder resources 

 

Notes from UPPO’s state administrator survey:

  • Holder instruction manual has been updated in the past three months.


Delaware
Report due: March 1, 2019
Extensions: Extensions may be requested.


Contact: escheat.holderquestions@delaware.gov or (302) 577-8782
Delaware holder resources.

 

Notes from UPPO’s state administrator survey:


Florida 
Report due: April 30, 2019
Extensions: Extensions may be 
requested.


Contact: EReporting@MyFloridaCFO.com, (850) 413-5522
Florida holder resources.


Illinois 
Report due: May 1, 2019
Extensions: Extensions may be requested.


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

 

Michigan

Report due: July 1, 2019

Extensions: No details provide.

 

Contact: TreasUPDReporting@michigan.gov or (517) 636-6940

Michigan holder resources.

 

Notes from UPPO’s state administrator survey:

  • New website URL: https://unclaimedproperty.michigan.gov
  • Updated holder instruction manual/handbook expected soon.
  • Holders can now report properties and remit payments electronically.
  • HDE files no longer accepted.
  • Holders are expected to provide as much identifying, verifying information as possible. Without all information, claimants sometimes are referred back to holders for verification purposes.
  • Holders with nothing to report are able to submit a zero/negative report online. 
  • Because CEPAS has changed its company ID, holders will need to update their information with a new number provided on the payment website. 
  • EFT is required at the time of filing.

 

New York 
Report due: March 10, 2019
Extensions: Extensions may be requested. 

Contact: NYSRPU@osc.state.ny.us or (800) 221-9311
New York holder resources.

 

Notes from UPPO’s state administrator survey:

 

Pennsylvania 
Report due: April 15, 2019
Extensions: Extensions may be requested.  

Contact: report@patreasury.gov or (800) 379-3999
Pennsylvania holder resources. 

Texas

Report due: July 1, 2019

Extensions: Does not accept extension requests.

 

Contact: up.holder@cpa.texas.gov or (800) 321-2274

Texas holder resources.

 

Notes from UPPO’s state administrator survey:

  • Holder instruction manual has been updated in the past three months.

 

Vermont 
Report due: May 1, 2019
Extensions: Extension requests may be submitted to the Unclaimed Property Division of the State of Vermont Office of the Treasurer. Describe the circumstance(s) for the delay and indicate the anticipated report delivery date.


Contact: tre.upcompliance@vermont.gov or (802) 828-2407
Vermont 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:  spring reporting  unclaimed property 

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2018 Spring Reporting Checklist

Posted By Administration, Thursday, February 8, 2018

Spring reporting season is again upon us. Several states require holders to file reports between March 1 and July 2. 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. 

 

Connecticut 
Report due: March 29, 2018
Extensions: Extensions may be 
requested.


Contact: Maria Greenslade:
maria.greenslade@ct.gov or (860) 702-3125
Connecticut holder resources.


Delaware
Report due: March 1, 2018
Extensions: Extensions may be 
requested.


Contact: 
escheat.holderquestions@state.de.us or (302) 577-8782
Delaware holder resources.


Florida 
Report due: April 30, 2018
Extensions: Extensions may be 
requested.


Contact: 
EReporting@MyFloridaCFO.com, (850) 413-5522
Florida holder resources.


Illinois 
Report due: May 1, 2018 
Extensions: Extensions may be 
requested.


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

 

Michigan

Report due: July 2, 2018

Extensions: Extensions may be requested.

 

Contact: TreasUPDReporting@michigan.gov or (517) 636-6940

Michigan holder resources.

 

Notes from UPPO’s state administrator survey:

  • We will begin accepting online reporting in fall 2018.
  • We strongly suggest that negative (zero) reports be submitted to us. This is a process that should be much easier when our new system goes live in the fall of 2018.
  • We have a preferred cover sheet, but will accept other cover sheets that include name, address, FEIN, amount, and contact person.
  • Report submission: If you have Gonzalo Llano or Terry Stanton in the "Attn" field, either name should be replaced with "Attn: Holder Processing"

 

New York 
Report due: March 10, 2018
Extensions: Extensions may be 
requested. 

Contact: NYSRPU@osc.state.ny.us or (800) 221-9311
New York holder resources.

 

Notes from UPPO’s state administrator survey:

Pennsylvania 
Report due: April 15, 2018
Extensions: Extensions may be
requested.  

Contact: report@patreasury.gov or (800) 379-3999
Pennsylvania holder resources

Tennessee
Report due: May 1, 2018 
Extensions: Extensions may be
requested.

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

Notes from UPPO’s state administrator survey:

  • ReportItTN.gov is our portal that holders must use to report using NAUPA file and make payment.
  • Notice timing: Changed to no sooner than 60 days and no longer than 180 days. See TCA 66-29-128.
  • Notice language: See 66-29-129 for changes.
  • Required due diligence methods: Added email. See 66-29-128.
  • We recently passed a version of the new Uniform Law. The biggest impact is change in dormancy from five years to three years for most property types. Holders will need to report this May 1 property that meets dormancy of three, four and five years.

Texas

Report due: July 1, 2018

Extensions: Does not accept extension requests.

 

Contact: up.holder@cpa.texas.gov or (800) 321-2274

Texas holder resources.

 

Vermont 
Report due: May 1, 2018
Extensions: Extension requests may be submitted to the Unclaimed Property Division of the State of Vermont Office of the Treasurer. Describe the circumstance(s) for the delay and indicate the anticipated report delivery date.


Contact:
tre.upcompliance@vermont.gov or (802) 828-2407
Vermont 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:  spring reporting  unclaimed property 

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2017 Spring Reporting Checklist

Posted By Administration, Tuesday, March 14, 2017

Spring reporting season is again upon us. Eleven states require holders to file reports between March 1 and July 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. 

 

California 
Report due: Life insurance companies are required to file a Holder Notice Report by April 30, 2017; all other holders are required to submit a Holder Remit Report between June 1-15, 2017 
Extensions: Extensions may be
requested no later than 30 days before the due date.

Contact: updholderoutreach@sco.ca.gov or (916) 464-6284 
California holder resources.

Connecticut 
Report due: March 31, 2017
Extensions: Extensions may be 
requested.


Contact: Maria Greenslade:
maria.greenslade@ct.gov or (860) 702-3125
Connecticut holder resources


Delaware
Report due: March 1, 2017
Extensions: Extensions may be 
requested.


Contact: 
escheat.holderquestions@state.de.us or (302) 577-8220
Delaware holder resources.


Florida 
Report due: May 1, 2017
Extensions: Extensions may be 
requested by April 30


Contact: 
EReporting@MyFloridaCFO.com, (850) 413-5522
Florida holder resources.


Illinois 
Report due: May 1, 2017 
Extensions: Extensions may be 
requested and must be submitted in early April. 


Contact: 
Email form, (217) 785-6998
Illinois holder resources.

 

Michigan

Report due: July 1, 2017

Extensions: Extensions may be requested.

 

Contact: TreasUPDReporting@michigan.gov or (517) 636-6940

Michigan holder resources.

 

New York 
Report due: March 10, 2017 
Extensions: Extensions may be 
requested 30 days prior to the report deadline. 

Contact: NYSRPU@osc.state.ny.us or (800) 221-9311
New York holder resources.


Pennsylvania 
Report due: April 15, 2017
Extensions: Extensions may be
requested.  

Contact: report@patreasury.gov or (800) 379-3999
Pennsylvania holder resources

Tennessee
Report due: May 1, 2017 
Extensions: Extensions may be
requested by May 1.

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

Texas

Report due: July 1, 2017

Extensions: Does not accept extension requests.

 

Contact: up.holders@cpa.texas.gov or (800) 321-2274, ext. 66246

Texas holder resources.

 

Vermont 
Report due: May 1, 2017 
Extensions: Extension requests may be submitted to the Unclaimed Property Division of the State of Vermont Office of the Treasurer. Describe the circumstance(s) for the delay and indicate the anticipated report delivery date.


Contact:
tre.upcompliance@vermont.gov or (802) 828-2407
Vermont 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:  spring reporting  unclaimed property 

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