Unclaimed Property Focus

Delaware Creates Unclaimed Property Task Force

Fri, 17 Jul 2026 18:16:29 GMT

On July 1, 2026, the Delaware legislature passed the state’s Bond and Capital Improvements Act, which was signed into law on July 6 by Gov. Matt Meyer. Section 71 of the law establishes an Unclaimed Property Task Force, “empowered to inquire into, examine, study and make findings and recommendations to promote the stability and predictability of Delaware's revenue source of unclaimed property, as well as fairness, transparency, and predictability of the Delaware program to Delaware entities and property owners, including with regard to the reunification of unclaimed property with its owner.”

The task force will include:

A member of the Senate Majority (who shall serve as a co-chair) and a member of the Senate Minority.
A member of the House Majority (who shall serve as a co-chair) and a member of the House Minority.
The secretary of state or a designee appointed by the secretary.
The secretary of the Department of Finance or a designee appointed by the secretary.
The controller general or a designee appointed by the controller general.
A representative from the governor’s office.
Four members of the public, two appointed by the president pro tempore and two appointed by the speaker of the House.

The task force must provide a report to the state’s executive and legislative branches by Feb. 1, 2027.

On July 16, 2026, Delaware Gov. Matt Meyer signed Executive Order 26, aimed at establishing enhanced conflict-of-interest standards for executive branch members serving on Delaware’s Unclaimed Property Task Force.

Executive Order 26 prohibits executive branch representatives on the task force from having financial interests related to the unclaimed property industry during the previous five years, including compensated lobbying, consulting, audit, compliance, litigation, asset recovery or government relations work involving unclaimed property matters.

The order directs the Department of State to develop a conflict-of-interest disclosure form within 30 days, collect completed forms from executive branch members and designees, request voluntary disclosure from all other task force members and publish completed disclosures on the task force’s public webpage before its first meeting. It also requires disclosure status to be reflected in the minutes of each task force meeting.

In the order, the governor also encourages the House and Senate to apply the same standards to their task force appointees.

Finders Keepers? N.Y. Supreme Court Grapples with Unclaimed Bitcoin

Sun, 12 Jul 2026 18:59:51 GMT

A New York State Supreme Court legal battle over unclaimed bitcoin seeks a court decision on who has the right to abandoned cryptocurrency.

The complaint in ABC Company et al v. John Does claims that, beginning in December 2024, plaintiff Noah Doe located and subsequently turned over to the New York Police Department three batches of digital crypto wallets that had been inactive for five years or more. After seeking the owners for approximately a year, the NYPD returned more than 39,000 as-yet unclaimed wallets to Doe.

Doe discovered these wallets after identifying a security issue that left digital wallet owners unable to withdraw their contents, leading them to abandon the wallets. He then developed an algorithm to identify such abandoned wallets. He removed any wallets from the results that were held by third parties, leaving only self-custodied wallets.

Doe and two companies he controls are seeking a court declaration naming them as the owners of the abandoned wallets, which are reported to hold more than 3.7 million bitcoins, worth nearly $300 billion. The plaintiffs claim that the owners of these wallets, “…made a conscious decision to assume the risk of losing the private key by not using a third-party custodian.”

If the court were to rule in favor of the plaintiffs, it is unlikely the ruling would be enforceable, according to industry analysts.

Be(in) Crypto reports, “Bitcoin itself operates without any central authority capable of enforcing a forced ownership transfer. Thousands of independent node operators globally maintain the protocol. None of them would implement a change to satisfy a court order.”

Similarly, Cointribune argues, “The danger lies in the domino effect. If the Noah Doe strategy progresses, other claims could target dormant addresses, historic wallets, or long-held funds… The real issue is not just Noah Doe. It is whether a court can confuse patience, forgetfulness, and abandonment. For holders, the answer directly affects Bitcoin security and the legal value of self-custody.”

In June, the court paused the case, pending a July 14 hearing on an amicus brief raising questions about the potential precedent-setting nature of a court decision in favor of the plaintiffs.

“A ruling accepting Plaintiffs' theory could open the door to systematic exploitation of long-dormant Bitcoin wallets by parties who run computational searches of the public blockchain, submit USB drives to police, and seek judicial declarations of ownership: effectively creating a private industry of "Bitcoin finders" operating under color of lost property law,” the brief submitted by attorney Ian R. Cohen said.

On July 10, 2026, the Bitcoin Policy Institute, a cryptocurrency industry group, notified the court of its intent to intervene as a defendant, claiming that a decision in favor of the plaintiffs would significantly harm it, as well as other crypto investors who buy and hold digital currency as a long-term investment.

UPPO will continue to monitor and report on noteworthy developments with this case.

June 2026 President’s Message

Tue, 23 Jun 2026 00:11:17 GMT

With the first months of my UPPO presidency underway, I want to first thank all of those folks who helped me get comfortable in Board of Directors service last year. All my fellow board members showed me how to contribute effectively to the board’s work. Also, the great UPPO staff offered all of the guidance I needed. A year ago, I was still pretty sure I was going to mess this all up. So far, I haven’t, and I am optimistic about my year leading UPPO.

One of the things I have latched onto is the idea of “board service” because that really describes what happens. All of the decision-making that is done is for one purpose – serving the needs of the UPPO membership and keeping all of those holders, service providers, advocates and other industry professionals well-informed and supported.

Notice that I named several of the categories we tend to divide ourselves into. When it comes right down to it, though, we are all holders. Holders have obligations to the people we all serve – property owners. The entire goal of this exercise we call escheatment is to ensure that people and businesses can always be reunited with the property that is rightfully theirs. No business or government is without a debt owed to an owner or constituent.

Throughout this year, I hope to help our organization keep a focus on that obligation and to foster continued collaboration between the UPPO and the states to drive the best service we can to the owners of the world. UPPO’s Strategic Plan envisions our organization as “the bridge between our members and the states to identify, educate and implement common ground solutions to benefit all stakeholders.”

In the banking industry, we talk about the concept of “holder in due course.” While the definition of that term from the Uniform Commercial Code deals with checks and other negotiable instruments, the idea applies to all UPPO members. Until a debt is settled, it remains outstanding – due and payable if you will. In our work, we establish a chain of custody; the initial holder passes that debt to the state which becomes the new holder. The goal is to eventually settle that debt by returning it to the rightful owner.

For several years, the UPPO Annual Conference’s tagline has been, “Sharpen Your Focus.” That is my goal – a laser focus on getting this all right. The right people focused on the right processes and procedures, the right legislation and policies, the right collaborations, the right education, and ultimately, the right property into the hands of the right owners. I look forward to working with all of you toward that goal along the way. You are the right people for all of this.

We all have talents and ideas to contribute, so let’s get to it. Our organization depends on all of our skills and expertise. I encourage you to participate in UPPO at whatever level you can, and I look forward to the progress we’ll make together this year. I need your feedback, so if you have ideas on how UPPO can better serve the unclaimed property community, please reach out to me. Thank you for trusting in me and supporting me. I’m excited to work with you and on your behalf in the coming year.

Delaware Removes Illicit Property Reporting Guidelines

Thu, 18 Jun 2026 22:41:11 GMT

Last summer, the Delaware Office of Unclaimed Property published guidelines for the reporting of illicit property when holders believe an owner is using a false identity. The link to those guidelines has since been removed from the state’s website (although the PDF document is still available).

A Delaware unclaimed property administrator noted the removal of the guidelines during a fraud session at the National Association of State Treasurers’ Treasury Management Training Symposium, attended by UPPO representatives on June 15-18, 2026. According to the comments, the published guidelines raised significant questions, prompting the state to work on more precise guidance.

Also discussed during the NAST session, the National Association of Unclaimed Property Administrators Fraud Committee is developing model language for reporting illicit property. However, it remains a work in progress, and Delaware’s likelihood of adopting the NAUPA language is unclear.

UPPO will continue to track developments related to both Delaware’s and NAUPA’s illicit property guidelines and will report noteworthy updates.

Arizona Implements Voluntary Early Review Process

Fri, 12 Jun 2026 16:58:20 GMT

The Arizona Unclaimed Property Department recently published details regarding an early review process for this year’s fall reporting cycle. The state is asking holders to submit a preliminary report by July 4, 2026.

Because this request and the tight timeline are likely to create challenges for UPPO members, and it doesn’t appear Arizona currently has the statutory authority to demand a preliminary report, UPPO representatives reached out to Arizona for clarification.

State officials clarified that the early review process is a request and is not statutory. As such, participation is voluntary and not required.

Following is Arizona’s request to holders regarding the new process:

Dear Holder Representative.

The Arizona Unclaimed Property Unit is implementing an early review process for the upcoming annual reporting cycle ending November 1, 2026.

We request that your organization submit a preliminary NAUPA II report file no later than July 4, 2026 (120 days prior to the statutory deadline). Please note the following specific requirements for the early submission.

No Remittance: this is a data-only request. Do not send any funds, checks, or electronic transfers with this early report. Payment is only due upon the final filing on or before November 1.
Contact Phone Number: Please provide your customer service phone number.

Please Note: This early report neither relieves the holder of its early obligation to perform statutory due diligence nor meets the requirements of filing an annual report under A.R.S. §44-307.

Please email your files to AZ_UnclaimedProperty@azdor.gov, the Department’s secure Holder Reporting email. Should you have questions, please contact the Unclaimed Property team at (602) 716-6031 or AZ_UnclaimedProperty@azdor.gov.

Thank you for your cooperation in ensuring the integrity of Arizona’s Unclaimed Property Program.

Building an Effective Unclaimed Property Compliance Program

Fri, 5 Jun 2026 11:36:47 GMT

Developing, implementing and maintaining an effective unclaimed property compliance program is vital for any property holder.

A company’s compliance program needs to be calendar-driven, aligned with reporting deadlines and state-determined due diligence requirements. Maintaining a calendar that includes timing for each compliance program step helps unclaimed property professionals stay organized and on track throughout the year. The calendar should also factor in pertinent internal timing, such as the amount of time it takes for checks to be issued.

Because state requirements that drive the steps in a compliance program can change, it’s important to stay up to date. To help holders keep up with changes, UPPO posts spring and fall reporting guides annually, and most states provide updates on their websites or within their holder reporting guides.

Although compliance programs vary from company to company, most share several similar steps.

Data Identification and Gathering

Because reporting unclaimed property depends on a review and analysis of company records, the most common first element in a compliance program is identifying and gathering the data needed to develop an accurate report. This step typically includes:

Coordinating all divisions, departments and other entities.
Understanding unclaimed property requirements for each property and holder type.
Creating a repository for documentation gathered during the reporting cycle.
Developing a checklist to verify the submission of all necessary data.

Item Review

Before attempting to contact owners whose property is identified as potentially abandoned, holders should review and refine gathered records. This step includes identifying duplicate items; improperly voided or reversed items from previous periods; and special items needing additional handling, such as high-value property.

Due Diligence

A critical compliance program component, due diligence consists of outreach to apparent property owners – usually by letter – before filing unclaimed property reports with the states. Due diligence not only ensures compliance with state unclaimed property laws and regulations, but can also boost customer relations.

Reconciliation

After sending due diligence letters, the reconciliation step reviews and documents the results. This step includes recording and responding to responses from the due diligence process. For example, if a property owner requests an uncashed check be reissued, the corresponding record would be removed from the list of unclaimed property needing to be reported upon reissuing payment. As with all steps, documentation is essential to create a paper trail that may be needed in the event of an unclaimed property audit.

Exemption Application

Before reporting, review company policies regarding business-to-business and other statutory exemptions. Identify property types eligible for exemption and any state-specific nuances for taking exemptions. Some companies decline to take advantage of available exemptions, so knowing not only what exemptions may be available but also whether your company routinely takes advantage of them is essential.

Reporting

After each of the previous steps has been completed, it’s time to report unclaimed property to the states. Because state requirements vary, it’s important to understand the nuances for applicable states, property types and holder types. Similarly, each state requires compliance with its specific policies and capabilities for electronic filing and payment. Identify applicable filing requirements, deadline dates, acceptable payment methods, and required signatures and notarizations before submitting your reports.

Outreach and Reclaim

Once everything is filed with the state, follow company policies for due diligence responses that come in after the deadline. Know whether the company prefers to pay the owners and request amounts back from the states, or instead directs owners to the state to recover their property.

DEIB Spotlight: Raaja Vengatesan

Tue, 19 May 2026 17:55:35 GMT

DEIB Spotlight is a UPPO DEIB Committee initiative that celebrates the organization’s diversity by highlighting members who help make UPPO a welcoming association for all unclaimed property professionals.

In recognition of May being Asian American and Pacific Islander Heritage Month, we’re shining the DEIB Spotlight on Raaja Vengatesan, an unclaimed property tax associate for Baker Tilly.

Raaja Vengatesan’s path to unclaimed property began more than 8,000 miles from the Chicago area, where he now lives and works. Born in Thiruppanandal, a village in the Indian state of Tamil Nadu, Vengatesan moved to the United States with his family when he was seven years old. Since settling in the Chicagoland area in 2008, he has remained closely connected to both his Indian heritage and the local Hindu community that helped shape his upbringing.

“My dad is a priest, so we’ve always been very involved in the religious community,” Vengatesan said. “Growing up, I spent a lot of weekends at the temple for summer camps, religious events and community gatherings. Even after moving to the U.S., we stayed very connected to our culture and traditions.”

Most of Vengatesan’s extended family still lives in India, and throughout his childhood, he returned every few years during summer breaks to visit relatives. As recently as this month, he returned to India again for a major religious festival held in his family’s village.

“It’s a really big event that only happens every few years,” he said. “The entire extended family gathers in the village where my dad grew up. It’s been really meaningful to maintain those connections.”

As he prepared to graduate from the University of Illinois Urbana-Champaign in 2024 with degrees in accounting and finance, Vengatesan explored multiple career paths through internships in both finance and forensic accounting. While considering his next step, he realized the accounting side of the profession aligned more closely with his interests and strengths.

That search led him to an opportunity in unclaimed property consulting at Baker Tilly – though initially, he had no idea what unclaimed property actually was.

“When I first saw the job posting, I thought it involved real estate,” Vengatesan said. “During the interview, they explained what unclaimed property really was and the type of work involved. Once I learned more about it, I realized it was actually a really interesting mix of accounting, compliance and consulting.”

Nearly two years into his career in unclaimed property, Vengatesan appreciates how dynamic and varied the work can be.

“You still get the technical accounting and compliance side, but there’s also a lot of problem-solving and creativity involved,” he said. “Every client is different, every industry is different, and every state has different rules and requirements. There’s always something new to learn.”

One of the key traits that has helped him succeed, he believes, is the ability to balance attention to detail with a broader understanding of the bigger picture.

“In unclaimed property, details matter a lot because there are so many reports, schedules and requirements,” he said. “But it’s also important to step back and understand what those details mean overall. Looking ahead and anticipating issues before they happen has been really helpful.”

Vengatesan believes unclaimed property offers an appealing career path for professionals who want something less repetitive than traditional accounting roles while still benefiting from a strong technical foundation.

Although still early in his career, he says he can see himself staying in the unclaimed property profession long term.

“I feel like I’ve reached the point where I have a good grasp of the fundamentals, even though there’s still so much to learn,” he said. “That’s exciting because it feels like there’s a lot of room to continue growing.”

For now, he remains focused on learning, growing and contributing wherever possible – an approach shaped by both his professional experiences and the strong sense of community that has remained central throughout his life.

“I think being involved, staying curious and being willing to learn from others makes a huge difference,” he said. “That’s something I’ve carried with me both personally and professionally.”

NAUPA Provides NAUPA III Transition Update

Wed, 13 May 2026 13:52:35 GMT

The National Association of Unclaimed Property Administrators recently provided an update about the transition to the NAUPA III reporting format:

Following our recent discussions regarding the transition to the NAUPA III Reporting Format, we are reaching out to share a significant update to our implementation timeline.

While we initially targeted a Fall 2026 start, we have listened closely to your feedback regarding the scale of the proposed changes. We recognize that moving to an XML file format while simultaneously adopting a massive overhaul of property codes presents a significant technical and operational challenge. To ensure a smoother transition for holders, state vendors, and software providers, we are shifting to a two-phase rollout.

Phase 1: Spring 2027

The first phase focuses on the transition to the XML infrastructure without the immediate pressure of a completely new code set.

Format: Reporting will move to the XML format, utilize new validation tools, and allows for a more robust reporting structure, including many new fields and descriptions, to streamline the claims process for owners.
Code Structure: We will maintain the traditional NAUPA II property code elements with a few essential "tweaks" — specifically to accommodate essential new property codes.
Goal: This phase is designed as a manageable "test run," allowing all parties to learn the complexities of XML reporting and validation before the full schema is implemented.

Phase 2: TBD

The second phase will introduce more comprehensive property code restructuring. Our focus for this phase is to keep codes as similar to the current format as possible while ensuring the new standard meets modern reporting needs.

Enhanced Compatibility: Building on previous drafts, this phase will introduce a new property code listing with updated descriptions.
Cross-walk Guide: To simplify the transition, we will provide an inclusive cross-walk guide mapping old codes to new ones.

We believe this phased approach balances the need for modernization with the practical realities of the reporting environment. Please review the attached document and changelog to review the most current file format. We are working to update the Github xml/xsd to match, but there may be inconsistencies we will address.

We hope you will join us at the NAUPA Uniformity Committee meeting on May 27th at 2pm ET to review this new format and answer your questions. Register today.

We appreciate your continued engagement and look forward to working together through these milestones.

Sincerely,
The NAUPA Uniformity Committee

Litigation Update: Knellinger v. Young Allowed to Continue

Mon, 4 May 2026 02:47:53 GMT

Following last April’s reversal by the U.S. Court of Appeals for the 10th Circuit of a 2023 district court dismissal of Knellinger et al v. Young et al, the state of Colorado again filed a motion to dismiss, claiming, in part, immunity under the 11th Amendment.

On Feb. 13, 2026, the district court dismissed most claims, agreeing with the state’s position. However, the court allowed the case to proceed on allegations that state officials failed to follow Colorado’s notification process before taking property, thereby violating the plaintiffs’ right to due process.

The case was brought in 2022 by plaintiffs David Knellinger and Robert Storey, who alleged that Colorado’s Department of Treasury failed to provide notice before taking their abandoned property and, thus, violated the U.S. Constitution’s 5th Amendment Takings Clause and 14th Amendment Due Process Clause.

“Although Plaintiffs will ultimately be required [to] carry the burden of ‘establish[ing] the personal participation of each defendant’ in order to establish § 1983 liability at trial… the Court is satisfied that Plaintiffs have, for now, alleged facts sufficient to create an affirmative link between Defendants’ responsibilities and the alleged procedural due process violations that survive Defendants’ instant dismissal motion,” the court wrote.

View the February 2026 district court opinion.

April 2026 President's Message

Sat, 25 Apr 2026 00:51:32 GMT

Over the past year, it has been my privilege to serve as your UPPO president. With that said, I’d like to take a few minutes to reflect on some of the accomplishments I’m most proud of – accomplishments that truly belong to this organization and to all of you.

I want to start with the incredible work we did in our summer board meeting, notably updating UPPO’s strategic plan. As a board, we took a look at where we are today, where we want to go and what it will take to get there. The result is, in my view, a comprehensive plan to help:

Grow our organization’s longevity.
Deliver lasting impact to the unclaimed property community.
And further develop the skills and careers of our professionals.

This strategic plan is not just a vision statement. The plan is supported by a defined set of tactics that touch every part of UPPO and provides details for how we will accomplish our goals. We wrote or reaffirmed tactics spread across various priorities, ranging from:

How we encourage more participation and engagement from members.
How we structure and prioritize our advocacy efforts.
How and when we partner with other organizations.
And even how we present ourselves and tell our story through a more thoughtful social media strategy.

I’m confident that what the board has laid out will guide UPPO for years to come.

Second, I’m especially proud of our continued collaborative relationship with NAUPA and state unclaimed property administrators. This has been a priority for us for several years, and each year we’ve seen that partnership deepen in meaningful ways. A great example is our recent collaboration on fraudulent reporting guidance, where we worked together to address an issue that affects both holders and states, and ultimately, the owners we all serve. We similarly worked together on virtual currency topics and have even started to collaborate on educational content for the possible next iteration of our certificate/credential program.

At this year’s UPPO Annual Conference, we took that collaboration a step further by piloting our State Office Hours – another way we are building bridges, encouraging dialogue and making it easier for members and state representatives to connect in a constructive, solution-oriented environment.

Third, we continued to evolve our committee structure to keep pace with the issues you face every day. We created new task forces, and one of those has already become a standing committee – our Operational Compliance Committee. This committee will work hand in hand with GRAC, with a specific and practical focus on operational compliance issues: the “how do I actually do this?” questions that holders wrestle with in real time.

On the topic of advocacy, UPPO’s Government Relations and Advocacy Committee (GRAC ) was as busy as it has ever been this year. GRAC has continued its efforts to provide input and feedback to numerous states on proposed legislation and regulations. UPPO has submitted comment letters to several states, including (but not limited to) Florida, Minnesota, Maine, New York and Ohio. In addition to written commentary, GRAC members have recently met virtually with Arkansas, Minnesota, Maine and others, resulting in substantive and meaningful dialogue providing states with industry perspective and offering workable alternatives that benefit not only holders but the states as well. GRAC’s efforts have resulted in a number of states making amendments or important changes to regulations, creating a clearer pathway for compliance and reporting.

In addition to its work on legislation and regulations, GRAC has been active on the legal front. As directed by the Board of Directors, GRAC members drafted and submitted an amicus brief to the Michigan Supreme Court supporting Disney in the Disney v. Eubanks case. UPPO voiced concerns, including that the rule would have a significant negative impact on the business community, because it would require businesses to either maintain voluminous records forever or risk facing unfounded demands for property that is not owed (and for which they no longer have adequate records to defend themselves). The rule is not only unfair and inconsistent with statutory text but could also pose serious due process concerns in the absence of clear advance notice.

GRAC will continue its efforts to engage in useful dialogue with states to support better compliance, reporting, and, ultimately, the return of property to rightful owners. Their work continues to ensure that UPPO is a respected, credible voice when laws and policies are being shaped that impact our members.

Their work continues to ensure that UPPO remains a respected, credible voice in shaping laws and policies.

And finally, we have the UPPO Annual Conference. With the strongest post-COVID registration numbers we’ve seen, we can confidently say we’re back. The way this premier event continues to evolve, develop and grow just astounds me – timely topics, deeper dives into specialized issues and new ways to network and learn from one another.

From strategy and advocacy to collaboration, to the evolution of our committees and the conference, this has been a year of building for the future – strengthening the foundation for UPPO’s next chapter.

I’m incredibly proud of what we’ve accomplished together over the past year, and I’m confident we’ve put UPPO on a strong path for 2026/26 UPPO President Tom Powers, the incoming board and all of you to continue moving forward.

More Congressional Scrutiny of State Unclaimed Property Practices

Fri, 17 Apr 2026 17:37:57 GMT

On April 16, 2026, Sen. Elizabeth Warren (D-Massachusetts), Ranking Member of the Senate Banking, Housing, and Urban Affairs Committee, sent a letter to the National Association of Unclaimed Property Administrators (NAUPA), raising concerns and seeking data regarding recent trends in states escheatment laws that govern how owners can reclaim lost or forgotten property and when states can seize the assets.

Warren’s request occurred on the same day U.S. Reps. Sam Liccardo (D–California) and Mike Lawler (R–New York) introduced the bipartisan Safeguarding Americans’ Fairly Earned Retirement Act of 2026 (SAFER Act), which aims “to stop states from seizing Americans’ savings through escheatment laws.”

“Trends in state escheatment laws may be increasing the likelihood that property is designated as unclaimed and turned over to state governments,” Warren wrote. “(M)any states have started adopting a more aggressive ‘inactivity’ standard… This is exacerbated by the fact that states have also moved to shorten their dormancy period to three years from five.

“Shortening dormancy periods and starting the clock at the first sign of inactivity in many ways undermines the most common and often prudent strategy for investing, which is to ‘buy and hold.’ Many workers investing for retirement are not constantly checking their accounts, as expected with an investment management professional.”

Warren requested that NAUPA provide information regarding state unclaimed property practices by May 1, 2026, including:

The method each state uses to trigger the dormancy period.
Each state’s dormancy period for the escheatment process related to financial accounts and include if each state’s dormancy period was shortened in the past 10 years.
A state-by-state breakdown of how much state reserves of escheated funds haveincreased over the last 10 years.
The total number of unclaimed property held by states.
An overview of the role auditors play in the escheatment process, including but not limited to, how states employ them, the scope of services included in states’ engagement of auditors, and the typical compensation structure states use to pay them.
NAUPA’s policy position regarding changes to the state dormancy period and whether or not a state should use an “inactivity” or “RPO” standard?
Insights into the motivation for states changing their laws to switch from an “RPO” standard to an “inactivity” standard and shortening their dormancy period.
How NAUPA collaborates or coordinates policy positions with any other organizations that inform state treasurers on escheatment law.

View Sen. Warren’s letter.

Federal SAFER Act Could Reshape Financial Institution Escheatment

Thu, 16 Apr 2026 19:26:37 GMT

On April 16, 2026, U.S. Reps. Sam Liccardo (D–California) and Mike Lawler (R–New York) introduced the bipartisan Safeguarding Americans’ Fairly Earned Retirement Act of 2026 (SAFER Act). The bill aims “to stop states from seizing Americans’ savings through escheatment laws,” according to a press release published by Liccardo.

“Your invested savings should stay yours, but too many states seize Americans’ hard-earned money with too little accountability,” Liccardo said. “States shouldn’t steal grandma’s hard-earned savings to build sports stadiums. We’ve introduced the SAFER Act to stop the government-sponsored cash grabs that victimize too many older Americans.”

The SAFER Act bars states from escheating securities, digital assets or non-ERISA retirement accounts unless and until a financial institution confirms the asset owner has died. The bill is intended to protect long-term investors and retirees from losing hard-earned savings they reasonably expect to access later in life.

"States have been able to raid Americans’ savings under the guise of ‘unclaimed property,’ leaving families blindsided when they discover their investments were seized or liquidated without real cause,” Lawler said. “By requiring a confirmation of death before any escheatment, we’re protecting retirees, long term investors, and every American who plays by the rules and expects their hard earned money to be there when they need it.”

View the SAFER Act bill , along with an FAQ and Fact Sheet published by Liccardo's office.

Litigation Update: Delaware Escheat Process Challenge Continues

Sun, 12 Apr 2026 23:11:18 GMT

A lawsuit challenging the constitutionality of Delaware’s unclaimed property compliance law, Vial v. Mayrack et al., will continue, following the recent denial by U.S. District Court Judge Maryellen Noreika of a motion to dismiss.

The case alleges that Chilean man Rene Borquez owned stock held in several U.S. financial services accounts. Following his death in 2006, Delaware seized the stocks without prior notice. In 2017, as legal representative of Borquez’s heirs, plaintiff Jamie Vial contacted Delaware’s Office of Unclaimed Property, requesting the property’s return and providing documentation supporting his claim. Following “extensive communications,” he received two checks in January 2023, totaling more than $2.5 million.

“The final sum received by Plaintiff is grossly inadequate,” the suit argues. “It fails to reflect the current market value of the stock and fails to put Plaintiff in the same position monetarily as he would have occupied if the property had not been seized and taken by Defendants.”

The defendants argued that the plaintiff is seeking a different unclaimed property system, which the state is not constitutionally required to offer for these reasons:

Plaintiff does not have standing.
The statute of limitations bars claims for the Borquez property escheated under the prior version of the DUPL.
The amended complaint fails to state a takings claim.
The amended complaint fails to state a due process claim.
The Eleventh Amendment either precludes a challenge to the DUPL or precludes the plaintiff from receiving a money judgment, thereby rendering his claim toothless.

In denying the dismissal motion, the court found the defendants’ arguments unpersuasive. As it relates to the Eleventh Amendment argument, the court highlighted confusion over Delaware’s Escheat Special Fund:

“Considering both the Amended Complaint and the DUPL, it is unclear how the allotment or payment of monies from the Escheat Special Fund actually operates, and whether the Eleventh Amendment applies… Clarifying that issue is relevant to the case and can be resolved in relatively short order. Accordingly, the parties are directed to meet and confer and submit a joint schedule for conducting expedited discovery regarding the Escheat Special Fund.”

The judge ordered the parties to submit a joint schedule for expedited discovery regarding the operation of the Escheat Special Fund within 30 days.

View the court’s denial of the defendant’s motion to dismiss.

Unclaimed Property Continues to be a Popular Fraud Target

Fri, 3 Apr 2026 13:31:15 GMT

Several news stories over the past six months highlight that unclaimed property remains a popular target for scammers seeking to get their hands on funds belonging to others.

WCTV reported on the arrest of a California man accused of making a series of false unclaimed property claims against the Florida Division of Unclaimed Property. He allegedly succeeded in receiving at least $10,000 from his claims by using a stolen Social Security number and forged documents, including a death certificate.

WSB-TV reported on an Atlanta man who allegedly submitted seven fraudulent unclaimed property claims with the Massachusetts Unclaimed Property Division. Three of the claims resulted in a $1.1 million payout. The false claimant is accused of using falsified documents, call and mail forwarding, fake identification and phony bank accounts to perpetrate his scheme.

WNEM shared news that three accused unclaimed property fraudsters had pleaded guilty to four felony charges in Michigan. Charges included Conspiracy to Commit False Pretenses over $100,000, Uttering and Publishing, Forgery, and Using a Computer to Commit a Crime to falsely claim a $579,000 payment.

At least one state has recently taken measures to combat unclaimed property fraud. The Center Square reported on a new Wisconsin law making it a felony to intentionally file a false unclaimed property claim in the state.

Unclaimed Property Pros Gather in San Antonio for UPPO Annual Conference

Wed, 18 Mar 2026 17:47:01 GMT

UPPO’s 2026 Annual Conference brought more than 650 unclaimed property professionals to San Antonio, Texas, on March 15-18 for dozens of educational sessions and networking events designed exclusively for unclaimed property holders, service providers, claimant representatives and state administrators.

Educational Sessions

The UPPO Annual Conference’s agenda featured expert speakers and panelists discussing the many nuances of unclaimed property compliance. This year’s session topics included digital assets, loyalty programs, legal issues, audits and dozens more. Attendees also participated in industry-specific breakout sessions and heard from state administrators.

State Office Hours

As part of UPPO’s ongoing focus on building strong relationships with state agencies and facilitating greater one-on-one connectivity between holders and state unclaimed property administrators, UPPO provided states with an opportunity to participate in our first State Office Hours.

This new initiative provided an opportunity for informal, open conversations between states and holder attendees. The format created space for questions, dialogue and shared understanding in a relaxed environment outside of formal sessions. Nine administrators representing eight states participated.

Networking Events

The conference also featured many opportunities for attendees to check in with old friends and make new connections. Meals, breaks and receptions provided additional time to talk shop each day. The UPPO Scholarship Program hosted a boat tour of the San Antonio River Walk, and Tuesday night’s special event featured refreshments, entertainment and an all-around good time at the historic Alamo.

Board of Directors

2025/26 UPPO President Will King thanked members of the 2025/26 UPPO Board of Directors for their service, and immediate past president Freda Pepper installed the next board, which begins its service on May 1:

President Tom Powers
Vice President Leigh Underwood
Treasurer Jon D’Amato
Secretary Melissa Steinrock
Director at large Laurie Andrews
Director at large Debbie Pyle
Director at large Jamie Ryan
Director at large PJ Sheets
Director at large Pamela Wentz
Director at large Gina Winston
Immediate Past President Will King

Sponsors and Exhibitors

The UPPO Annual Conference would not be possible without the support of sponsors and exhibitors. Thank you to all of the vendors who helped make this year’s event a success.

Exhibitors included:

Aprio Advisory Group
AssetFynd
Baker Tilly
Boomerang Asset Recovery
Citrin Cooperman Advisors LLC
Crowe LLP
DuCharme, McMillen & Associates Inc.
Dunbar
Eisen
Financial Software Innovations
FRS UP
Georgeson
Kodiak Solutions
Linking Assets
MarketSphere Unclaimed Property Specialists
New York Post
NY Daily News
The Petersen Group LLC
Reed Smith LLP
Ryan LLC
SafeChief - YottaFlex.ai
Scripta LLC
Sovos
Yellow Tag Auctions

Sponsors included:

Alston & Bird LLP (Corporate)
Andersen (Mobile App)
Aprio Advisory Group (Corporate and In-Kind)
Armanino Advisory LLP (Corporate)
Bailey Cavalieri LLC (Room Keys)
BDO USA (Corporate)
CBIZ Advisors LLC (Corporate)
Crowe LLP (Corporate Premier)
Deloitte Tax LLP (Corporate)
FRS UP (Corporate)
KPMG (First-Time Attendee Reception)
McDermott Will & Schulte LLP (Registration)
Morris, Nichols, Arsht & Tunnell LLP (Snack Kits)
The Petersen Group LLC (Corporate)
PwC US Tax LLP (WiFi)
RSM US LLP (Elevator)
Ryan LLC (Swag Bags)

Atlanta 2027

Thank you to the attendees, speakers, industry ambassadors and members who helped plan this year’s conference. Your passion, knowledge and participation made this year’s event a success. Join us next year in Atlanta on March 7-10 for the 2027 UPPO Annual Conference. Planning is already underway, and it’s sure to be another must-attend event.

UPPO Scholarship Program Announces Annual Recipients

Wed, 18 Mar 2026 14:12:51 GMT

One of UPPO’s programs that allows members to give back to our professional community and support each other is the UPPO Scholarship Program. To date, it has awarded more than 20 UPPO families scholarships to support full-time study at an accredited institution. This year, the Scholarship Program awarded two $2,500 renewable scholarships.

This year’s first scholarship recipient this year is Maura Lawler, the niece of UPPO member Heather Steffans from MarketSphere. Maura is a senior at Dubuque Senior High School in Dubuque, Iowa. She plans to study architecture at a university to be determined. She is involved in cheerleading, tennis, Green Team, Speech, Silver Cord, Model UN and the National Honor Society, and currently serves as the student body president.

This year’s second scholarship recipient is Meredith Carlson, whose mother is UPPO member Nicole Carlson from Modern Woodmen of America. Meredith is a freshman at the University of Iowa, majoring in health promotion on the pre-med track. In addition to her academic work, she is a patient care technician in the Neonatal Intensive Care Unit at University of Iowa Hospitals and Clinics.

Congratulations to Maura and Meredith for their achievements, and best of luck with their future academic endeavors.

Thank you to this year’s Scholarship Program sponsors: Barganier & Associates, Baker Tilly, MarketSphere Unclaimed Property Specialists, Kodiak Solutions, Ryan LLC, Jim Sadik, Unclaimed Property Consulting & Reporting LLC, Mike Ryan, The Petersen Group, Anthony Vitellozzi, Meagan Lehman and Global Shareholder Services.

UPPO Announces 2026 Award Winners

Tue, 17 Mar 2026 01:13:23 GMT

Each year during the Annual Conference, UPPO recognizes the hard work and dedication of association members whose efforts contributed to the success of UPPO and the unclaimed property profession throughout the past year. They deserve recognition and appreciation for their hard work, leadership, teamwork and passion.

Congratulations to all of this year’s winners for their selfless dedication and commitment to their association and profession.

Members’ Choice Awards

With the Members’ Choice Awards, UPPO recognizes specific state administrators and unclaimed property programs for their excellence. UPPO members nominate candidates and choose the winners from the subsequent slate of nominees. Congratulations to this year’s recipients:

Team Player Award/State MVP – Post-Escheat: This award is given to the state official who has gone above and beyond to collaborate with UPPO to promote more owner-friendly processes and improved reunification rates. This year’s winners are Joani Bishop and Melissa Sosebee from Texas. They are committed to advancing owner-friendly processes and improving reunification outcomes. They are reliable, efficient and consistently collaborative. Over the years, they have demonstrated unwavering responsiveness, meticulous attention to detail and proactive communication, resulting in a claims process that is not only predictable but remarkably seamless. Among their outstanding team, Melissa especially exemplifies the highest standards of professionalism and service. She is exceptionally easy to work with, friendly and consistently timely in her review of claims. Importantly, she applies the proper evidentiary standards and reasonably interprets statutes and regulations, always with the goal of ensuring rightful owners are reunited with their property. Her diligence extends beyond claim review: she willingly identifies and adds additional properties belonging to claimants when appropriate, further supporting reunification efforts.
Compliance Advancement of the Year: This award recognizes a state that has significantly improved its compliance program with process improvements and/or technological advancements to better facilitate the compliance process for the holder community. This year’s winner is California for eliminating the USF-1 coversheets. Holders no longer need to sign and upload additional documents, making it more efficient for holders to do their jobs when filing unclaimed property reports. This creates a more streamlined and consistent process for holders to follow. The elimination of the USF-1 coversheet is a big deal for many holders.
Unclaimed Property State Representative of the Year: This award recognizes a state administrator or staff person who has gone above and beyond to assist the holder community. This year’s winner is Melissa Sosebee from Texas, who has consistently gone above and beyond to support the claimant rep community, providing clear guidance and timely assistance on complex issues that help reunite owners with their funds. Her proactive communication and willingness to collaborate make her an invaluable resource for both claimant representatives and industry professionals. In every sense of the word, Melissa is a gold standard professional. She consistently demonstrates responsibility and sound judgment, ensuring every step of the process is clear and efficient. Her practical approach and commitment to making the experience seamless reflects a high level of professionalism. She is great to work with and deserves recognition.

Team Player Awards

This award is presented to volunteers who serve on committees, work diligently on projects that advance the work of their committees and help pull the team together to accomplish their goals.

This year’s first recipient is Wilson Barmeyer. He has been a valued member of our Government Relations and Advocacy Committee and will be wrapping up his term as that committee’s chair. Thanks to his leadership, GRAC has further improved its processes and had a positive impact on several pieces of legislation on behalf of the unclaimed property community.

The second recipient is Jen Borden. She has been extremely helpful to the Claimant Representatives Committee and its work on securities-related issues. She’s always willing to share her time and knowledge for the betterment of the unclaimed property compliance environment, and we’re fortunate to have her as part of UPPO.

This year’s final recipient is Dana Terry. She has a long history of working on behalf of our association and profession. Her recent work with two committees earned her this year’s Team Player Award. Our new Operational Compliance Task Force’s work requires open communication and collaboration with GRAC. Having the right person serve as the liaison between those committees has been essential to getting the new committee off the ground and functioning effectively.

Shining Star Awards

Eleven UPPO members received Shining Star honors for their “shining brightly to help guide the way” by demonstrating strong leadership and reliable commitment. Each of these recipients has provided outstanding service to the committees on which they serve or special projects completed for the organization. This year’s Shining Stars are:

For their service on our Board of Directors, Michael Finkelstein and Michael Giovannini. These two have contributed their leadership skills, knowledge and creativity to help guide UPPO and ensure it continues to serve the unclaimed property community.
For her work representing UPPO on the Holders Coalition and working on several comment letters for GRAC, Melissa Steinrock.
For chairing the new Operational Compliance Committee, Ann Loperfito.
For her work as chair of the Speaker Subcommittee for this Annual Conference, Ann Fulmer.
For his hard work on the Conference and Seminars Committee as well as being the driving force behind our recent article in the San Antonio Business Journal, George Tsofilas.
For their contributions to UPPO’s education and advocacy causes, tireless advocacy advancing holder interests and frequent service as extremely popular speakers for UPPO, Michael Rato and Ethan Millar.
For being a consummate volunteer for UPPO and the reason many of us, including me, are involved in UPPO, as well as her assistance to me serving as a sounding board and providing the history behind many of UPPO’s initiatives, Karen Anderson.
For his consistent assistance with education and speaking about technical topics, Grant Faustino.
And for his long-time work on the Claimant Representatives Committee, where he is wrapping up his term as chair, Scott Pettinato.

Award of Merit

This award is typically given to member organizations that have provided exceptional support to UPPO during the past year. This year, UPPO recognized Bailey Cavalieri LLC and Reed Smith LLP. These companies provided their expertise and countless hours to write an amicus brief on behalf of UPPO for the very important Disney case. UPPO also recognized Brian McCarthy for his guidance of UPPO’s work on the increasingly important issue of virtual currency through his work as chair of the Virtual Currency Task Force.

President’s Award

This award, chosen by the association’s president, honors a member who has taken on a huge task or project that will help change or improve the unclaimed property profession for years to come. This year’s recipient, Freda Pepper, is completing her service on the UPPO Board of Directors. Currently UPPO’s Immediate Past President, Freda served as vice president in 2023/24 and as president in 2024/25. Her leadership has helped propel UPPO’s strategic initiatives around advancing the work of the Diversity, Equity, Inclusion and Belonging Committee, and building our relationships with the states, seeking common ground and collaborating toward shared goals. Without question, UPPO is more well off thanks to Freda’s contributions.

Super Nova Award

UPPO’s Super Nova Award is not given each year, as it is a very special recognition and UPPO’s highest honor. This year, we are posthumously recognizing one of UPPO’s longtime members, Diann Smith, whom we unfortunately lost recently. UPPO was truly fortunate to have someone as knowledgeable in unclaimed property and state and local tax law as Diann. She served as a member and co-chair of the Government Relations and Advocacy Committee, where her insight helped navigate complex legislation and litigation and supported the drafting of amicus briefs. She was also a beloved presenter at conferences and webinars, known for her dry humor, sharp perspective, and unforgettable roles in mock trial presentations.

At the heart of everything Diann did was a deep commitment to educating others. She genuinely cared about helping professionals grow and about strengthening the unclaimed property community as a whole.

Many UPPO members came to treasure the lighter moments she brought to virtual meetings, when her sweet cats would prance across the screen or curl up on her shoulders as she continued speaking without missing a beat. Those moments captured Diann perfectly — brilliant, kind, and wonderfully human. Her loss will be felt for many years to come, but we’re grateful for her many years of contributions to UPPO and the unclaimed property community.

Congratulations, UPPO award winners.

Is AI Effective for Unclaimed Property Fraud Detection?

Fri, 13 Mar 2026 20:20:14 GMT

Organizations and individuals are using artificial intelligence to solve countless problems. In the world of unclaimed property, it may be a useful tool for addressing fraud. A recent UPPO webinar, Unclaimed Property Fraud: Red Flags & Prevention Strategies, addressed the strengths and weaknesses of using AI technology as a fraud-identification tool.

Strengths

Identity Theft and Document Forgeries: AI is generally effective at catching identity theft and document forgeries. It can often spot fake IDs and Social Security cards that look authentic to the eye. It can identify small inconsistencies, such as altered seals or mismatched fonts that humans might miss.

Organized Fraud Networks: AI can link data across thousands of claims, connecting shared addresses, phone numbers and bank accounts. It can also quickly process data to reveal large, coordinated schemes. It could take humans several weeks or longer to analyze the same data.

Repeat Offenders: AI can recognize repeat fraud offenders through pattern recognition. It can also identify behavioral similarities. For example, certain unclaimed property claimants may file claims only on weekends or in the evenings, using the same IP address. AI can spot those claims and flag them as suspicious.

Real-time Data Cross-Referencing: AI can compare data from multiple databases, including public records, genealogy sites, claim histories and prior communications with claimants. Analyses that would take a human much longer to complete can be accomplished by AI quickly and with fewer errors.

Anomaly Detection and Continuous Learning: AI improves with use, adapting to new fraud tactics, helping it prevent future schemes. The more data it processes, the better it becomes at separating legitimate claims from suspicious ones.

Weaknesses

Constant Maintenance: AI requires constant maintenance. Fraudsters evolve, so AI must be regularly updated to stay sharp and effective.

Privacy Concerns: AI requires a lot of data to learn, and much of it is personal in nature when it comes to unclaimed property. Understanding how that data is stored, used and protected.

False Positives and Negatives: AI is imperfect. If you use ChatGPT or a similar AI engine regularly, you’ve likely received erroneous information several times. As such, AI can flag legitimate unclaimed property as suspicious or miss fraudulent claims entirely.

Human Oversight: AI still requires human oversight. It’s very effective at recognizing patterns, but it still hasn’t perfected interpreting context or intent. People need to review AI’s findings, apply reasoning and make the final call on many claims.

False Sense of Security: AI can breed complacency. Overconfidence in AI’s capabilities can create gaps that fraudsters will gladly exploit. Technology should assist, not replace, human judgment.

Cost and Transparency: Building and maintaining AI systems takes time, money and technical expertise, and it isn’t always transparent. Sometimes AI will flag claims without explaining why. This can delay and complicate training and future policy decisions.

Artificial intelligence is a powerful tool in the fight against unclaimed property fraud. However, it’s not a standalone solution. The best results are likely to come when technology and people work together to stay a step ahead of the fraudsters.

UPPO members who wish to learn more about unclaimed property fraud can access a recording of the Unclaimed Property Fraud: Red Flags and Prevention Strategies webinar on UPPO’s On-Demand Webinar Library.

SURCH Program Streamlines Uncashed Retirement Plan Check Reporting

Thu, 5 Mar 2026 13:38:09 GMT

In an effort to streamline the reporting of uncashed retirement plan distribution checks, state governments have partnered with the U.S. Department of Labor, the National Association of State Treasurers and the National Association of Unclaimed Property Administrators to develop the States’ Unclaimed Retirement Clearing House.

Administered by NAUPA, SURCH is available to retirement plans and plan record keepers, with no reporting fees. Participating states cover all costs.

SURCH is designed to:

Streamline the reporting of uncashed checks by plans through “one-stop filing” for as many states as possible.
Relieve retirement plans of burdens associated with maintaining and administering uncashed plan distribution check records.
Provide a safe-harbor disposition for uncashed plan checks that is consistent with Department of Labor requirements.
Reunite retirement plan participants with their lost funds through the unclaimed property outreach programs of the various states.

Currently, participants can use SURCH to report uncashed checks aged more than 12 months, in the amount of $1,000 or less, issued to a plan participant with a last known address in 35 eligible states and the District of Columbia. SURCH is working with other states to join the program, aiming for 100% participation.

To learn more, download reporting templates and submit reports online, visit the SURCH website.

Which States Are Most Collaborative?

Tue, 24 Feb 2026 23:29:01 GMT

UPPO is occasionally asked which states are the most collaborative with property owners and employ policies that result in the reunification of unclaimed property.

In recent years, UPPO’s Claimants Representative Committee has nominated states and individual state representatives to receive UPPO’s State MVP and Platinum Procedures Awards in recognition of their work to return property to its owners.

Nominees are those states that enjoy a comparatively high rate of property return or make significant legislative changes to assist owners and promote reunification. Specifically, the CRC nominated:

Florida for outstanding cooperation with claimant representatives, transparency of information and timely claim processing.
Georgia for comprehensive revisions to its unclaimed property statutes designed to increase reunification.
Texas for a long history of fair and reasonable procedures.
Mark Bracken from Massachusetts, for his dedication to reuniting owners with their property.
Kelly Kuracina from New York, for her dedication to owner claims and her efforts to efficiently process them.

In addition to these well-performing states and administrators, Walter Graham, who passed away last year, was nominated for a Lifetime Achievement Award for his long dedication to building Florida’s unclaimed property program into the consistently highest-performing program in the nation, as measured by the percentage of property returned to owners.

2026 Spring Unclaimed Property Reporting Guide

Thu, 12 Feb 2026 14:58:12 GMT

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 31, 2026
Extensions: Extensions may be requested

Contact: CTHolderReport@ct.gov or (800) 833-7318
Connecticut holder resources

Delaware

Report due: March 1, 2026
Extensions: Extensions may be requested by completing the “Filing Extension Request” form in the Holder Handbook.

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

Florida

Report due: April 30, 2026
Extensions: Extensions may be requested by email by the reporting deadline.

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

Illinois

Report due: May 1, 2026
Extensions: Extensions may be requested.

Contact: UP_Report@IllinoisTreasurer.gov or (217) 785-6998
Illinois holder resources.

Michigan

Report due: July 1, 2026
Extensions: Extensions may be requested by email. Include company name, holder ID or FEIN and reason for extension

Contact: TreasUPDReporting@michigan.gov or (517) 636-6940
Michigan holder resources.
Notes from UPPO’s state administrator survey:

Holder reporting manual/handbook available.
State now offers educational videos highlighting how to upload or file an unclaimed property
State does not have a pre-presumption outreach requirement.
An online portal is acceptable for capturing responses to due diligence letters or pre-presumption outreach.
State does not require securities dividends to be totaled by owner and reported as a lump sum amount for reporting.
State does not require a cover sheet.
Holders are strongly encouraged to file reports electronically via the state’s secure website. No additional documentation is needed if filed electronically.
State's system does not have any formatting requirements that might cause a file to be rejected.
State's systems does not accept a test file.
State does not require holder number.
Report submission formats accepted: electronic upload
Report file formats accepted: HRS, TXT (preferred)
Remittance options: ACH debit (preferred), check.
State does not require online payment at the time of electronic filing. Holders can pay at a later date by clicking the link in the confirmation email.

New York

Report due: March 10, 2026
Extensions: Extensions may be requested.

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

Pennsylvania

Report due: April 15, 2026
Extensions: Extensions may be requested.

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

Texas

Report due: July 1, 2026
Extensions: No extensions will be granted.

Contact: up.holder@cpa.texas.gov or (800) 321-2274
Texas holder resources.
Notes from UPPO’s state administrator survey:

Holder reporting manual/handbook available.
State does not have a pre-presumption outreach requirement.
An online portal is acceptable for capturing responses to due diligence letters or pre-presumption outreach.
State does not require securities dividends to be totaled by owner and reported as a lump sum amount for reporting.
State does not require a cover sheet.
State's system does have formatting requirements that might cause a file to be rejected: Missing last contact dates, relationship codes.
State's system does not accept a test file via secure file transfer portal available at claimittexas.gov.
State does not require holder number.
Report submission formats accepted: electronic upload
Report file formats accepted: HRS, RPT, TXT (preferred).
Remittance options: ACH credit, ACH debit, check, wire.
State requires online payment at the time of electronic filing. Details.
Remittance options: ACH debit (preferred), check.
Test payments may be submitted after contacting TEXNET at 800-531-5441- ext.3-3010

Vermont

Report due: May 1, 2026
Extensions: No information provided

Contact: unclaimed.property@vermont.gov or (802) 828-2407
Vermont holder resources.

Notes from UPPO’s state administrator survey:

Holder reporting manual/handbook available.

Administrator Survey Updates from Other States

Arkansas:

Holder reporting manual/handbook available.
New website feature: Finalized Unclaimed Property Administrative Rules
An online portal is acceptable for capturing responses to due diligence letters or pre-presumption outreach.
State does not require securities dividends to be totaled by owner and reported as a lump sum amount for reporting.
State does not require a cover sheet.
Reports must be submitted online.
Formatting requirements that might cause a file to be rejected: Must be in NAUPA standard format. Reporting of addresses from other states, except for money orders and other similar items. If a report contains multiple or all items reported without a mailing address, state will want to confirm this with the holder because its mission is to return every penny to its owner.
State's systems does accept a test file, although not preferred.
State does not require holder number.
Report submission formats accepted: electronic upload (preferred), enter a manual report on the state’s website.
Report file formats accepted: TXT
Extension requests will be denied if it is received after the reporting deadline. If the relief requested is greater than 120 days, the request may be offered but with only a 120-day window [unless an act of God prevents such reporting].
Online payment required. Any request for exception must be made in writing and confirm that the holder will work to be able to submit payment online.
Payment is due upon acceptance of the report. In other words, if the report is rejected for correction, the state only wants the holder to submit the amount that is due.
Before making an online payment, please make sure your banking institution has released any debit blocks (if applicable) for Originator ID 1522077581 to ensure the payment processes successfully. Details.
If the holder chooses to pay with a credit card, there will be a fee. Otherwise, there is no fee.
Administrative rules were adopted on 11/3/2025.

District of Columbia:

Holder reporting manual/handbook available.
State does not have a pre-presumption outreach requirement.
Online portal is acceptable for capturing responses to due diligence letters or pre-presumption outreach.
State does not require securities dividends to be totaled by owner and reported as a lump sum amount for reporting.
Cover sheet required if submitting hand key report but not if submitting via online portal.
State accepts electronic signatures. State will waive cover sheet notary requirement for remote employees.
State's system does not have any formatting requirements that might cause a file to be rejected.
State's systems does accept a test file. Email our holder team first prior to uploading.
State does not require holder number.
Report submission formats accepted: electronic upload.
Report file formats accepted: TXT.
Extension requests may be denied due to numerous previous requests.
Remittance options: ACH credit, ACH debit, wire.
ACH/wire transfer details: Bank: Wells Fargo ABA #: 121000248 Account#: 2000043154940 Title: District of Columbia Government/Unclaimed Property Ref Line: Your FEIN or Tax ID number, and name Company ID/Submission ID: Z536001131
Online payment is due at the time of filing.
State allows test ACH payments. Email holders.ucp@dc.gov prior to sending test.

Indiana:

Holder reporting manual/handbook available.
State does not have a pre-presumption outreach requirement.
Online portal is not acceptable for capturing responses to due diligence letters or pre-presumption outreach.
State requires a Report Submission Summary Sheet with annual report filing.
State accepts electronic signatures.
The file must be in NAUPA II format. Holder reports MUST contain the last known address, if known. Reporting this information is critical to the claiming process and reduces the chances that the owner will need to contact you to request documentation to support their claim. The owner relationship type link is available here.
Formatting requirements that might cause a file to be rejected: Holder reports must contain all owner information, if known. Reporting this information is critical to the claiming process and reduces the chances that the owner will need to contact the holder to request documentation to support their claim.
State's systems does not accept a test file.
State does not require holder number.
Report submission formats accepted: Electronic upload.
Report file formats accepted: TXT.
Extension request form must be accompanied by a detailed explanation on corporate letterhead that outlines the reason for seeking approval.
Remittance options: check, wire (preferred).
After a successful upload you will have the option to pay: Option #1: Mail a physical check to our office; Option #2: Electronic Payment – eCheck or Credit Card.
The Office of the Attorney General accepts Visa, MasterCard, Discover, and American Express with a convenience fee of 2.25% (minimum fee of $1.00) for both credit card and debit card payments. Also, eCheck payments are accepted with a convenience fee of $1.00. This convenience fee is nonrefundable.

Kansas:

Holder reporting manual/handbook available.
State does not have a pre-presumption outreach requirement.
Online portal is acceptable for capturing responses to due diligence letters or pre-presumption outreach.
State does not require securities dividends to be totaled by owner and reported as a lump sum amount for reporting.
State does not require a cover sheet or other form to be submitted with annual report.
State's system does not have any formatting requirements that might cause a file to be rejected.
State's systems does accept a test file. Please notify ksholder@treasurer.ks.gov that you are submitting a test file.
State does not require online payment at the time of electronic filing.
State does not require holder number.
Report submission formats accepted: CD, electronic upload (preferred), flash drive, paper.
Report file formats accepted: TXT.
Multiple extension requests may not be approved.
Remittance options: ACH credit, ACH debit (preferred), check, wire. Instructions.
Payment is due as soon as possible following report filing.

Maine:

Holder reporting manual/handbook available.
New website feature: Last July's holder training is available to view.
State does not have a pre-presumption outreach requirement.
An online portal is acceptable for capturing responses to due diligence letters or pre-presumption outreach as long as contact response is documented.
State does not require securities dividends to be totaled by owner and reported as a lump sum amount for reporting.
State does not require a cover sheet or other form to be submitted with annual report.
Required documentation/communication: Reports should be uploaded through the state's secure portal and payments are made either through the state's online payment portal (PayMaine) or by mailing a check. Securities should be remitted before the report due date.
Report file must follow NAUPA II reporting format.
State's systems does not accept a test file.
State does not require holder number.
Report submission formats accepted: electronic upload.
Report file formats accepted: TXT.
Incomplete extension request forms, including missing estimated amount and reason for extension will be rejected for completion.
Prepayment requirement: Estimated payment is due by November 1st for an extension request.
Remittance options: ACH debit (preferred), check.
Payment is due by Nov. 1 for non-insurance but should be close to the filing time.
Payment instructions.
Fees are only assessed only if the payment returns by the bank, including for lack of flagging the state safe from debit blocks.
Gift Obligation reporting stopped after 2024. Any gift obligation property reported will be returned to hold the liability until the obligation is redeemed per Maine statute.

New Mexico:

Holder reporting manual/handbook available.
State does not have a pre-presumption outreach requirement.
An online portal is acceptable for capturing responses to due diligence letters or pre-presumption outreach.
State requires securities dividends to be totaled by owner and reported as a lump sum amount for reporting.
State requires a signed cover sheet to be included with annual report.
State accepts electronic signatures. State will waive cover sheet notary requirement for remote
Report file must follow NAUPA II reporting format.
State’s system accepts test file. Email unclaimed.Property@tax.nm.gov.
State does not require holder number.
Report submission formats accepted: electronic upload.
Report file formats accepted: HDE (preferred), TXT
Prepayment requirement: Payment in the amount of what is thought to be reported as unclaimed property.

Wisconsin:

Holder reporting manual/handbook available.
State does not have a pre-presumption outreach requirement.
An online portal is not acceptable for capturing responses to due diligence letters or pre-presumption outreach.
State does not require securities dividends to be totaled by owner and reported as a lump sum amount for reporting.
State does not require a signed cover sheet to be included with the annual report.
Reports must be filed here.
State's systems does not accept a test file.
State does not require holder number.
Report submission formats accepted: electronic upload.
Report file formats accepted: TXT.
Habitual extension requestors may be denied.
Remittance options: ACH debit (preferred), check.
Online payment is due at the time of filing.

Wyoming:

State does not have a pre-presumption outreach requirement.
An online portal is not acceptable for capturing responses to due diligence letters or pre-presumption outreach.
State requires securities dividends to be totaled by owner and reported as a lump sum amount for reporting.
State requires a signed cover sheet with the annual report filing.
State accepts electronic signatures.
State's system does not have any formatting requirements that might cause a file to be rejected.
State's systems accepts a test file. Please notify office in advance.
State does not require holder number.
Report submission formats accepted: electronic upload.
Report file formats accepted: TXT.
Extenstion requests may be denied if holder has history or repeatedly seeking an extension.
Remittance options: ACH credit (preferred), check. Instructions.
State does not require online payment at the time of electronic filing.
Payment is due by Nov. 1.
$1 fee for ACH payment.

British Columbia:

Holder reporting instructions.
New website feature.
Province has a pre-presumption outreach requirement for all properties.
An online portal is not acceptable for capturing responses to due diligence letters or pre-presumption outreach.
Province requires securities dividends to be totaled by owner and reported as a lump sum amount for reporting.
Province does not require a signed cover sheet with the annual report filing.
Holders must use spreadsheet that is provided on the province’s website.
Province’s system does not accept a test file.
Province does not require holder number.
Report submission formats accepted: electronic upload.
Report file formats accepted: Excel (preferred), PDF.
Remittance options: check, wire (preferred), USD by cheque only.
Payment is required once approval for submission is given. Instructions.
Province updated its website and database at the end of 2025. Holders are encouraged to review the submission process before submitting funds.

New Brunswick:

Holder reporting manual/handbook available.
Province has a pre-presumption outreach requirement. Property generally becomes unclaimed after 3 years of inactivity. Holders are required to send written notice to apparent owners 3 to 6 months before reporting unclaimed property.
An online portal is acceptable for capturing responses to due diligence letters or pre-presumption outreach.
Province does not require securities dividends to be totaled by owner and reported as a lump sum amount for reporting.
Province does not require a signed cover sheet with the annual report filing.
All reporting is done through the online portal. There are three reporting methods: XML (preferred), CSV, or online form.
Fields are described in the Holder Reporting Manual. For XML and CSV files, there is a validation tool that the user must use before submitting a file. If required fields are not filled out correctly, validation will be unsuccessful and the user will have to correct the errors before resubmitting.
Province’s system does not accept a test file.
Province does not require holder number.
Report submission formats accepted: electronic upload.
Remittance options: check, wire, EFT (preferred).
Online payment is due at the time of filing. Instructions are included on the invoice after a report has been submitted.
Province does not charge fees but there may be fees for wire transfers charged by the bank.

Quebec:

Holder reporting manual/handbook available.
Province has a pre-presumption outreach requirement. For unclaimed financial assets, a holder of property that becomes unclaimed when dealing with unclaimed financial products must send the right holder a written notice at least three months in advance. This notice must: Describe the unclaimed financial product, and Inform the right holder that the property will be transferred to the Minister if it is not claimed within the required timeframe. This notice must be sent within the six-month period preceding the date on which the asset must be delivered to the Minister. However, the holder is exempt from sending this notice if: The right holder's address cannot be found using reasonable means, or the total value of all unclaimed financial assets belonging to the same owner or right holder is under $100.
An online portal is acceptable for capturing responses to due diligence letters or pre-presumption outreach.

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.

Reunification Policies to Maximize Unclaimed Property Recovery

Tue, 3 Feb 2026 14:21:00 GMT

State unclaimed property departments are intended to reunite property owners and their beneficiaries with unclaimed property held by the states. For example, Florida has promoted a “recovery-first” approach to unclaimed property, and Arizona has stated that reuniting owners with their lost assets is the heart of the state’s unclaimed property law and the program’s primary goal. In practice, however, certain administrative policies can make it more challenging to fully achieve these shared objectives.

UPPO’s Claimant Representatives Committee encourages the following key elements to be included in public policy to maximize recovery opportunities.

Notification and Information Access

Mandate regular, multi-channel outreach campaigns (email, mail, social media, public events) to increase awareness and engagement.
Ensure owners have access to unclaimed property administrators’ awareness efforts, including direct notifications from claimant representatives, to provide owners with the maximum opportunity to discover and recover their property.
Include all properties, regardless of value and age, on MissingMoney.com and state unclaimed property websites. Currently, many states exclude properties valued under $50.
Remove properties from state websites only after they have been returned.
Provide dynamic internet search options that incorporate advanced search logic on MissingMoney.com and state unclaimed property websites, enabling owners to locate properties even if their name has been reported in a format inconsistent with reporting requirements or misspelled, truncated or transposed.

Claimant Representative Services

Require claimant representatives to undergo periodic training on fraud prevention and ethical standards.
In addition to free state-provided claim support, ensure owners have access to paid claim services with minimal restrictions.
Repeal moratorium laws that prevent an owner from accessing fee-based claim service providers during these timeframes.
Adopt uniform recovery and investigator agreement disclosure requirements.
Waive fee restrictions under certain circumstances to ensure all owners can access claimant representatives’ services and capital.
Remit payment of claimant representatives’ fees and costs directly to the claimant representatives, and remit the balance to the owner.
Implement practical, uniform claimant representative registration requirements.
Exempt claimant representatives who represent only business entities from registration requirements, as the registration requirement laws primarily focus on consumer protection rather than businesses that made a deliberate choice to outsource their recovery process.

Streamline Property Return

Reduce evidentiary requirements for cash claims valued at $5,000 or less when claimants can match reported tax identification numbers and contact information provided by other state databases.
Leverage automation and digital workflows to reduce manual errors and accelerate claim processing.
Once claims become approved for funding, implement direct payment programs to remit unclaimed property to state child support collection and state tax agencies, after verifying that the debt has not been satisfied.
Create expedited processing procedures for vulnerable populations, such as seniors, disabled or low-income individuals, to ensure they receive their funds promptly.
Apply a uniform 90 or 120-day limit on the claim evaluation period with strict limits on exceptions.
Implement a uniform statutory unclaimed property program funding mechanism to ensure the program has adequate operating capital to fund daily operations, to pay claims and to retain staff sufficient to decide all claims within 120 days.

Transparency

Publicly display a uniform set of essential property identifiers and an indicator that a claim is in progress within the search results on MissingMoney.com and state unclaimed property websites. Essential identifiers include:
- Reported owner names
- Reported address
- Holder name
- Property type
- Property ID
- Date of last contact
- Reported year
- Cash amount
- Number of shares of stock
- Name of securities issuer or stock ticker symbol
Provide account information to registered claimant representatives for all properties not yet returned with the essential property identifiers upon request in a searchable digital format for the purpose of locating, notifying and offering recovery services to unclaimed property owners.
Publish annual return rates and audit outcomes on their UP website, including the amount reported, the amount returned and the aggregate amount of property not yet returned.
Increase transparency to help identify and promote policies that result in increased recovery.

Claim Evaluation

Allow claimants to upload claims securely and required documents online, reducing the need for mailing physical copies.
Provide timely and consumer-friendly claim evaluation.
Apply proper evidence standard, and reasonable application of statutes, case law and regulations.
In addition to permitting administrators to use tools such as TLO, IDI, and LexisNexis for fraud prevention and identity verification, allow claimants to use these same resources to establish entitlement.
Implement a real-time online claim status feature that allows claimants to view updates on their claim, including estimated timelines, paid dates and any additional information required to process payment.
Proactively add additional properties owned by the claimant to pending claims.
Establish a clear appeals process for denied claims, with defined timelines and escalation paths.

Collaboration and Communication

Form advisory councils with stakeholders (holders, claimants, claimant representatives, consumer advocates) to review and recommend policy updates.
Improve collaboration and communication between holders, unclaimed property administrators, owners and claimant representatives to promote understanding of each other’s perspectives and develop policies that advance the unclaimed property program’s primary purpose of maximizing the return of property to its rightful owner.

Public Awareness

Conduct public awareness campaigns to educate citizens about unclaimed property and how to search for and claim their assets themselves or with the help of a claimant representative.
Leverage partnerships with community organizations, employers and financial institutions to amplify outreach.

Policy Review

Regularly review and update policies to keep pace with evolving technologies and best practices in unclaimed property recovery.
Benchmark against states with the highest return rates and adopt proven innovations.

Training and Resources

Provide training and resources for unclaimed property administrators and staff to ensure they are equipped to handle claims efficiently and effectively.

Some states are incorporating these policies to carry out their unclaimed property return strategies. Wider, nationwide adoption of this entire package of policies would boost public awareness of unclaimed property, reduce roadblocks that prevent property owners from successful claims and, ultimately, help state administrators achieve their reunification goals.

India Seeks to Streamline Unclaimed Property Claims

Sat, 24 Jan 2026 21:53:36 GMT

According to recent estimates, approximately 1.08 lakh crore (nearly US$13 billion) in unclaimed funds are available for claim in India. The process for account owners to locate and claim those funds is often hampered by the country’s numerous unclaimed property search portals, based on property types. In addition to search platforms maintained by individual banks, insurance companies, investment issuers and retirement plan administrators, unclaimed property may appear in several asset-specific databases:

Bank deposits: Reserve Bank of India’s Unclaimed Deposits-Gateway to Access inforMation portal.
Mutual funds: Securities and Exchange Board of India’s Mutual Fund Investment Tracing and Retrieval Assistant.
Insurance: Insurance Regulatory and Development Authority of India’s Bima Bharosa portal.
Shares, unclaimed dividends, matured deposits/debentures, etc.: Minister of Corporate Affairs Investor Education and Protection Fund portal.

Recognizing the complexity for account owners, India’s Department of Financial Services Ministry of Finance is working with numerous entities to develop a common platform. Participants include the Reserve Bank of India (RBI), the Securities and Exchange Board of India (SEBI), the Insurance Regulatory and Development Authority of India (IRDAI), the Pension Fund Regulatory and Development Authority (PFRDA), and the Investor Education and Protection Fund Authority (IEPFA), along with banks, insurance companies, mutual funds and pension institutions.

In October 2025, Union Finance Minister Nirmala Sitharaman launched the nationwide Your Money, Your Right campaign to raise awareness of unclaimed property and encourage claims. Events in 477 districts resulted in claims totaling approximately 2,000 crore (US$218,000) in the final three months of the year.

Announcing the unified portal in November 2025, Department of Financial Services Secretary Shri M. Nagaraju said he expects the centralized search platform to launch soon.

Considerations for Using Third-Party Administrators

Fri, 16 Jan 2026 15:26:43 GMT

Third-party administrators provide useful services to businesses that may not have the capabilities or desire to handle their own unclaimed property responsibilities. TPAs provide a wide 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.

DEIB Spotlight: Health and Wellness in the New Year

Thu, 8 Jan 2026 15:08:46 GMT

DEIB Spotlight is a UPPO DEIB Committee initiative that celebrates diversity by highlighting topics and members that help make UPPO a welcoming association for all unclaimed property professionals.

Philosopher Ralph Waldo Emerson famously wrote, “The first wealth is health” in his book “The Conduct of Life,” published in 1860. More than 165 years later, this simple statement holds as true as ever. With the start of a new year, refocusing on health, wellness and self-care – both physical and mental – can set a positive tone for 2026, reduce stress and improve your overall well-being. Following are several healthy habits to consider implementing this year.

Take Vacation Time

Getting away from day-to-day routines improves mental health – especially when such vacations include fully disconnecting from work. A 2024 Harris Poll revealed that 78% of American employees do not use all of their allotted paid time off. When people do get away, they’re often not fully disconnecting. More than half take work calls, and 86% said they check emails from their boss during paid time off.

However, numerous studies have tied time off to improved physical and mental health. Vacations reduce anxiety and depression symptoms, lower the risk of heart attacks, decrease work burnout and ultimately make people more productive.

Get Social

With so many conveniences available on demand, it’s easier than ever for people to isolate and minimize contact, but social connection is important. According to the World Health Organization (WHO), social connection can reduce inflammation, lower the risk of serious health problems, foster mental health and prevent early death. It can also strengthen communities to make them healthier, safer and more prosperous. In contrast, loneliness and social isolation increase the risk of depression, stroke, heart disease, diabetes and cognitive decline.

WHO recommends taking simple steps to improve social connection, like reaching out to friends, putting down the phone to be fully present in conversation, greeting neighbors, engaging with common interest groups and professional organizations, or volunteering.

Don’t Skimp on Sleep

According to the Centers for Disease Control, adults need seven or more hours of quality sleep to help reduce illness, maintain a healthy weight, decrease stress and improve mood, and lower the risk of chronic conditions, including high blood pressure, stroke, heart disease and type 2 diabetes.

While it’s tempting to trim an hour or two of rest here and there in the name of productivity, maintaining consistent sleep hours and putting away electronic devices at least 30 minutes before bedtime contribute to better sleep habits.

Just Move

Countless studies have directly connected regular exercise with improved health. Physical activity promotes strength, offsets the negative effects of stress and improves mood. Health organizations recommend at least 150 minutes of moderate aerobic activity or 75 minutes of vigorous aerobic activity weekly.

Not everyone is cut out for long-distance running or bodybuilding. Finding activities that are enjoyable and maintainable is essential. Whether it’s walking, dancing, yoga, pickleball or bicycling, implement activities that are likely to stick and incorporate them into your daily routine.

Practice Mindfulness

Reducing the buzz of information overload, quieting the mind and being present in the moment reduces harmful stress. Much like physical exercise, habitual mindfulness practices provide countless health benefits. Incorporating mindful practices into daily routines is essential to maintaining them for the long term.

Focus on simple habits, like turning off electronic devices during meals, ending each day by spending a few minutes reflecting on something for which you are grateful, and adding at least a few minutes of concentrated breathing and meditation into your daily routine. Watch for signs of tension or anxiety, slow your mind and focus on the moment. A few deep breaths and some light stretching can work wonders.

Where to Begin

Not sure where to begin? The web holds a wealth of information about simple health and wellness practices, so next time you catch yourself doomscrolling on social media, stop, close the app, go to Google or Bing and search for simple tips for exercise, mindfulness, stress reduction, better sleep or whatever healthy practice you’d like to add to your routine.

December 2025 President's Message

Mon, 22 Dec 2025 13:29:00 GMT

Happy holidays! At this time of year, it’s always nice to reflect on and give thanks for the people who improve our lives. In addition to family and friends, I am genuinely grateful for the many people who make UPPO such an outstanding organization. We are fortunate to have a large community of tireless volunteers who serve on our board and committees, speak at our online events and Annual Conference and share their knowledge and expertise throughout the year. Our dedicated staff works hard every day to continue delivering our benefits and carrying out our initiatives. And you, our UPPO members, participate in our events, contribute your ideas and keep our organization strong. Thank you for making 2025 an outstanding year for UPPO.

As this year winds down, you may be thinking about setting goals for 2026. If you’d like to make professional and career development part of your new year plans, I encourage you to look to UPPO to help.

If you hope to make more professional connections and increase your unclaimed property knowledge, there’s no better opportunity than the UPPO Annual Conference. In addition to the outstanding educational lineup, the conference is designed to bring people together. We’re heading to San Antonio in March for three and a half days of learning from industry experts, networking and building community. Make sure to register by Jan. 15 for the early-bird rate.

Another excellent opportunity to advance your career is by pursuing an unclaimed property certificate. The Certificate Program helps unclaimed property professionals expand their understanding of unclaimed property practices and demonstrate their knowledge and professionalism by completing the program, passing a test and earning a certificate. The 2025/26 certificate program is underway, so you can register and begin working toward your basic or intermediate certificate immediately.

Throughout the year, we have many opportunities to stay connected and informed. Take full advantage of your UPPO member benefits. Participate in Industry Focus Conference Calls and live and on-demand webinars to keep current with unclaimed property trends and best practices. Refer to the Jurisdiction Resource Guide to ensure you’re following correct reporting requirements in each state and province, and read the weekly govWATCH email to monitor potential and upcoming updates to state compliance laws and regulations.

Whatever career development goals you set, I wish you great success in 2026. On behalf of the UPPO Board, we hope you had a festive holiday season and wish you a happy New Year.

Identifying Records for Unclaimed Property Review, Part II

Wed, 10 Dec 2025 16:14:49 GMT

When trying to identify outstanding unclaimed property obligations, property holders should conduct a periodic review of areas where potential exposure lies. Unclaimed property can result from property types other than the common areas discussed in last week’s blog post.

To help ensure that all potential property types and sources are being captured in the unclaimed property review process, following are several additional unclaimed property risk areas where to review.

Gift Cards

Sales of gift cards and gift certificate transactions may result in escheatable property. Review gift card or gift certificate reports that identify unredeemed gift card balances, whether generated internally or as part of services provided by a third-party administrator.

Holders should review the unredeemed gift card or gift certificate report to identify cards and certificates that have been inactive and are soon to become dormant. The dormancy period for unredeemed gift certificates and gift cards varies by state.

Dormant unredeemed gift cards and gift certificates may be escheatable. If the holder retains the owner or gift recipient’s address information, the unclaimed property laws for that address’s state will apply. If the holder does not retain address information, the laws of the holder’s state of incorporation or domicile will apply.

Some states do not require the escheatment of unredeemed gift cards. A vast majority of those states simultaneously require that the cards and certificates do not expire. This allows an owner to redeem the gift certificate or gift card into perpetuity. The holder should identify the applicable state law to determine whether the transaction is escheatable and what limitations may be put on the redemption of the card or certificate.

Equity

When evaluating equity for potentially escheatable property, include in the review outstanding dividends, other payments that are owed and outstanding to the shareholder, as well as the underlying shares. Many states require that if a dividend check is dormant and escheatable, the holder also escheat the underlying share related to the dividend.

Most holders employ a transfer agent to oversee their equity. The transfer agent’s duties usually include escheat review and annual compliance filing. Holders should request and maintain copies of all annual unclaimed property reports filed by the transfer agent on the holder’s behalf.

If the holder is conducting its own analysis of potentially escheatable equity transactions, review the report of shareholder activity. This report should include the date of the shareholder’s last account activity, as well as list the outstanding dividend check payments.

States vary on what information is considered sufficient contact to identify the shareholder’s last activity date, so check the applicable state provision for that determination.

Mineral Rights and Royalties

Some holders may hold potentially escheatable property in the form of mineral rights and royalties. If so, review the list of suspended accounts resulting from contact with the property owner. The determination of lost contact may vary depending on applicable state law, so the always verify what is considered lost contact.

Similar to the analysis of equity transactions, if the royalty is determined to be dormant and escheatable, be aware that some states require holders to remit all owed royalties with the outstanding payment. Some states have more stringent guidelines for reporting mineral rights and royalties, so be sure to research state statutes.

Insurance

Insurance companies have a number of unique transactions from other types of businesses that may become escheatable property. Besides the traditional unclaimed property scenario of uncashed checks resulting in unclaimed property, insurance companies need to conduct analysis on agent commission liability accounts to identify any dormant unpaid commission balances.

Also obtain and review records related to life insurance policies. The purpose is to identify policies that have matured but were not paid to the policy holder due to lost contact. These policies may be escheatable.

Obtain a listing of life insurance policies for which the death notice was received but the claim not paid. This often occurs because the beneficiaries cannot be found. Many states have enacted the Life Insurance Benefit Act, which requires companies to check policy inventory against the Death Master File on a regular basis.

Further, the holder should obtain and review a listing of unpaid annuities and inactive retained asset accounts to identify transactions that have become dormant and may be escheatable to the states. As with all property types, dormancy and escheat requirements vary by state, so holders should confirm the law with the applicable state.

Identifying Records for Unclaimed Property Review, Part I

Wed, 10 Dec 2025 16:06:43 GMT

When trying to identify outstanding unclaimed property obligations, property holders should conduct a periodic review of areas where potential exposure lies. To help ensure that all potential property types and sources are being captured in the unclaimed property review process, examine trial balances, general ledger and bank statements.

Bank Accounts

The review should identify all open and closed bank accounts used to distribute checks and electronic payments. For open accounts, verify that outstanding checks associated with the accounts are being captured in the unclaimed property procedures. Review closed accounts to determine the resolution of outstanding items. Examine voids to ensure they are well-supported and not being issued to circumvent unclaimed property.

General Ledger Accounts

Review general ledger accounts to identify accounts that have been established to capture unknown, unreconciled, write-off or suspense balances. If accounts are noted in the system, conduct additional research to verify whether the balances represent unclaimed property.

Uncashed and Voided Checks

Looking at uncashed checks is intrinsic to every unclaimed property review. Research checks outstanding more than 180 days to determine whether the funds remain due and payable to the payee. If the distribution is still owed, confirm payee name and address and conduct outreach to contact the payee about the status of the outstanding check. If the payee lost or destroyed the original check, void the original issuance and reissue payment. Always maintain notes pertaining to the reissuance in the accounting records, along with the date the reissued check cleared.

Review transactions voided greater than 90 days from issuance to verify that the reason for the void is documented in the accounting records and not simply because it was outstanding and not cashed.

Checks issued by third parties on behalf of the holder can create unclaimed property exposure for a company if responsibilities are not well-defined. Review third-party contracts to verify the duties are clearly outlined and documented, and those responsibilities are executed based on the contract terms. If the third party is reporting on the company’s behalf, request and maintain copies of the unclaimed property reports, detail of the reported property, and all associated payments and remittances to the state. Ultimate responsibility for the outstanding checks tends to fall back on the company unless adequate supporting documentation can be produced.

Credit Balances

Accounts receivable credit balances tend to be one of the most complicated accounting types in unclaimed property as a result of states holding various positions regarding when or if property is deemed reportable. In some states, accounts receivable credit balances are not reportable while there is an active relationship with the customer, but the state may not provide a thorough explanation of what constitutes an active relationship. Other states consider all credits as potential unclaimed property, no matter the account relationship, and want the holder to confirm that the customer is aware of the credit and has the opportunity to use it.

Most states also allow credits owed to a customer to be offset by balances owed to the company, but they have to be for the same customer. For example, a company cannot take Jim’s credit balance to pay Mary’s bad debt. Debits due from the customer that were written off to bad debt during the same time period can be used to offset the credit balance write-offs.

When conducting an analysis of the accounts receivable transactions that are potentially escheatable, look at transactions that may no longer be included in the receivables account. For example, such transactions may include credits that were reclassed out of accounts receivable and into accounts payable because they were refunded to the payee. The process should include reviewing reports that contain any unresolved credits that were reclassified out of the receivables account.

The holder should review the general ledger detail to identify any credit balances that were reclassified because these transactions may represent unclaimed property. The states do not accept write-offs to income as sufficient to remove the credit balance and, therefore, prevent the credit balance from being escheated to the state as unclaimed property.

Unapplied Cash Detail

Review the unapplied cash detail, also commonly referenced as an unidentified remittance, to identify any receipts that are stale-dated and have not yet been applied to a customer’s invoice to offset the credit. The determination of when the transaction is stale-dated may vary by state. The unapplied cash detail analysis may not be applicable if the holder maintains unapplied cash on the accounts receivable aging reports. In that case, review the aging reports on a regular basis.

Next week’s UPPO Unclaimed Property Focus blog post will discuss additional records to examine for potential unclaimed property.

Influential Companies Lend Support to Annual Conference

Mon, 1 Dec 2025 17:44:45 GMT

The 2026 UPPO Annual Conference is just a few months away. Scheduled for March 15-18, 2026, in San Antonio, the conference is built around the four dozen educational sessions covering nearly every relevant topic for unclaimed property professionals. However, the draw of the conference is not limited to education. The event features daily social activities, breaks and meals designed to help attendees reconnect with familiar faces and expand their network with other holders, service providers and state administrators.

These opportunities to learn, network and collaborate with others who “speak the same language” wouldn’t be possible without the many exhibitors and sponsors who support the event, UPPO and the greater unclaimed property compliance community.

Thank you to all of the companies that have already committed to exhibiting and sponsoring the 2026 UPPO Annual Conference. Interested service providers can learn about limited remaining exhibit and sponsor opportunities here.

Exhibitors

Aprio Advisory Group
AssetFynd
Baker Tilly
Boomerang Asset Recovery
Citrin Cooperman Advisors LLC
Crowe LLP
DuCharme, McMillen & Associates Inc.
Dunbar
Eisen
Financial Software Innovations
FRS UP
Georgeson
Kodiak Solutions
Linking Assets
MarketSphere Unclaimed Property Specialists
New York Post
NY Daily News
The Petersen Group LLC
Reed Smith LLP
Ryan LLC
SafeChief - YottaFlex.ai
Scripta LLC
Sovos
Yellow Tag Auctions

Unclaimed Property Fraud Webinar Follow-up Questions

Thu, 20 Nov 2025 00:02:10 GMT

UPPO’s recent Unclaimed Property Fraud: Red Flags and Prevention Strategies webinar identified red flags for potential unclaimed property fraud and strategies for defending against fraudulent claims. Because limited time prevented presenters from responding to some of the participant questions during the webinar, they kindly agreed to respond for publication on UPPO’s Unclaimed Property Focus blog. UPPO members can view the webinar via the On-Demand Webinars page.

How is AI used with personally identifiable information (PII)? Most companies don't allow PII to be entered into AI platforms?
You're right that handling PII with AI requires careful consideration. While many companies restrict direct entry of PII into public AI platforms, there are several compliant approaches. Secure AI solutions include:

Enterprise AI platforms with dedicated infrastructure and data protection agreements allow companies to process PII while maintaining compliance with privacy regulations like GDPR and CCPA.
On-premises or private cloud AI deployments keep sensitive data within company infrastructure.
AI tools can work with de-identified or anonymized data for analysis, removing direct identifiers while preserving analytical value.

The key is implementing appropriate safeguards. Companies should conduct privacy impact assessments before deploying AI solutions that touch PII, and ensure their AI usage aligns with their data governance policies and regulatory obligations.

Our accounts payable department has gotten very restrictive to vendor updates due to some fraud. What happens when fraud prevention impedes reissuing funds to claimants? If we withhold something from reporting because someone has returned a claim form but then doesn't submit all information that AP requires to reissue a payment, what do we do? Often with vendors set up a long time ago, we didn't have Tax ID's in our system so there isn't something to verify.
This is a challenging balance many organizations face – protecting against fraud while ensuring legitimate claimants receive their funds. Here's a framework for addressing this tension:

Create Tiered Verification Processes: Rather than applying the strictest standards uniformly, develop risk-based approaches. For legacy vendors/claimants without complete historical data, establish alternative verification pathways that provide reasonable assurance without creating impossible burdens.

Alternative Documentation Options:

For claimants lacking Tax IDs, accept other forms of verification such as notarized affidavits or business registration documents.
Implement a "weight of evidence" approach where multiple lesser documents collectively establish legitimacy.
For long-standing relationships, consider the payment history itself as verification evidence.

Reporting Obligations: Remember that fraud prevention cannot be used as a blanket excuse to avoid reporting unclaimed property. If someone has submitted a claim form but cannot provide every AP requirement, you need to determine: Is this a legitimate inability to provide documentation, or is it suspicious behavior? Document your analysis and decision-making process carefully.

Best Practice: Consider working with your legal and compliance teams to establish a policy that balances fiduciary responsibility, fraud prevention, and unclaimed property compliance obligations. This policy should specify what documentation is "reasonable" for various scenarios.

For fraud prevention, can you use an obituary to match the next of kin instead of the heirship form?
States will not accept an obituary on lieu of a table of heirship. A table of heirship is a legal document used to identify the rightful heirs of a deceased person for the purpose of transferring assets, while an obituary is a public notice announcing a death and memorializing the decedent’s life. Additionally, states will rarely accept an obituary to substantiate a relative referenced on a table of heirship as obituaries are too easy to fabricate. Instead, the states will look to certified vital records (birth, death and marriage records) to confirm next of kin, etc.

What steps can be taken to ensure states are not refusing to pay claims based on fraud when no fraud exists?
Please see the Evidence Standard blog post that was recently published by UPPO, as it includes excellent information on evidence standards.

Many states are raising their evidentiary requirements under the guise of combatting fraud. The Claimant Representative Committee has spent years advocating that the appropriate standard to apply to unclaimed property claims is the preponderance of the evidence standard. Not the higher “clear and convincing” standard used in civil matters or the “beyond reasonable doubt” standard used in criminal cases. This continues to be a challenging effort because states face two conflicting priorities: returning assets to rightful owners and preserving state revenue. Stricter evidence standards allow states to retain more funds while making the recovery process more difficult for claimants.

Depending on what type of organization you are trying to confirm ownership, I would encourage you to produce a copy of an IRS-Schedule C tax form if trying to confirm ownership of a sole proprietorship or an IRS-Schedule K1 to confirm ownership in a corporation/LLC. If no records exist, then perhaps a CPA or accountant that previously filed taxes for the company would be able to produce the records.

Common Healthcare Account Reporting Errors

Fri, 14 Nov 2025 14:41:25 GMT

Nearly every holder that reports unclaimed property to the states faces certain nuances unique to their industry. Being aware of some of the challenges and potential pitfalls of those nuances can help ensure reports contain fewer errors. Following are some of the common reporting errors healthcare providers face.

Proper owner

Healthcare providers receive payments from multiple payers on a single account. They include patients, insurance companies, patient guarantors and, if the patient has passed away, estate executors. Doing sufficient due diligence is essential to ensuring the correct property owner is listed on the report. For example, an account that shows a patient’s birth date was six years ago is a clear indication that person isn’t making the payment. Thus, it’s necessary to review the patient’s account to see who the patient guarantor is.

Social Security numbers vs. federal ID numbers

When remitting property to the state for an insurance company, ensure the field for a Social Security number or federal ID number lists the company’s federal ID number rather than the patient’s Social Security number. It is common for providers to inadvertently include the patient’s Social Security number, but doing so makes matching the account to the insurance company challenging.

Insurer’s last known address

The employees who enter information into the provider’s database are sometimes tempted to use shortcuts rather than thoroughly entering each piece of data properly. For example, they may enter “see address on insurance card” in the insurance company address field. Unfortunately, this presents a problem for the person filing the unclaimed property report, who doesn’t have access to patients’ complete records.

Multiple patient addresses

If a patient’s record includes both a physical address and a mailing address, it is essential to be aware of any restrictions placed on use of the physical address. Patients may specify that they do not want any correspondence sent to the physical address for privacy reasons. Particularly in the case of providers specializing in sensitive areas such as psychiatric care, patients may not want other people who have access to mail sent to the physical address to know about the care they are receiving. Multiple addresses also increase the chances of an incorrect city, state or ZIP code on the report. Ensure the information from these fields corresponds to the mailing address rather than the physical address.

Bipartisan House Bill Offers Relief for Unclaimed Retirement Benefits

Thu, 30 Oct 2025 19:03:44 GMT

On Sept. 11, 2025, Reps. Seth Magaziner (R-Rhode Island) and Ron Estes (D-Kansas) introduced H.R. 5325, legislation permitting states to use their existing unclaimed property programs for certain retirement plan accounts.

The Unclaimed Retirement Rescue Plan would:

Allow retirement plan administrators to voluntarily transfer unclaimed retirement distributions between $50 and $5,000 to state unclaimed property programs through the States’ Unclaimed Retirement Clearing House initiative, which is already used by states and private-sector benefit plan administrators.
Direct states to regularly update the Department of Labor’s Retirement Savings Lost and Found database so individuals can more easily track and recover their money.
Require the secretary of labor to report to Congress on the effectiveness of these regulations.

H.R. 5325’s introduction comes eight months after the U.S. Department of Labor’s Employee Benefits Security Administration published similar enforcement relief in Field Assistance Bulletin 2025-01. Unlike the recently introduced bill, which allows plan administrators to transfer unclaimed accounts up to $5,000 to state unclaimed property programs, the DOL guidance cap such transactions at $1,000.

The bill was referred to the Education and Workforce Committee and Ways and Means Committee, where it awaits further action.

Why Unclaimed Property Evidence Standards Matter

Thu, 23 Oct 2025 15:37:29 GMT

State unclaimed property administrators consistently promote returning property to its rightful owners as their top priority. Fulfilling this objective requires several factors to align:

Awareness: Owners must know the property exists.
Transparency: States need to disclose enough detail to generate confidence and interest in claiming the property.
Accessibility: The claim process needs to be fair and simple.
Reasonable Standards: Evidence requirements must consider real-world challenges faced by claimants.

During UPPO’s recent Evidence Standards webinar, members of the organization’s Claimant Representatives Committee shared the importance of reasonable evidence standards and the challenges that claimants face when standards make claiming property unnecessarily daunting.

“Proper evidence standards matter for a few reasons,” said Mark Warren, senior manager with Ernst & Young. “First, they ensure fair, consistent and reliable claim evaluations. They also help assess the credibility and minimize bias or fraud. Standards exceeding legal requirements reduce valid recovery. When the standards are too high, it makes the recovery process difficult. And, maximizing approved claims requires strict adherence to the preponderance standard.”

When evaluating evidence, there is a range of burdens of proof. The most onerous burden is proof beyond a reasonable doubt, which is used in criminal proceedings. Applying that standard to unclaimed property claims would be unreasonably cumbersome and would severely hinder reunification. Similarly, proof that is clear and convincing, which is sometimes used as a civil standard, is onerous and overly challenging for claimants.

Applying a preponderance of evidence standard is used for most civil proceedings, including unclaimed property. This standard requires claimants to prove they are more likely than not entitled to recover the property. Numerous legislative and regulatory requirements, as well as court decisions, reflect the common application of the preponderance of evidence standard to unclaimed property administrative proceedings.

Several types of evidence can be used to reliably prove property ownership. Government records are especially useful. These are routinely accepted by courts and are easily authenticated. For example, filings with any secretary of state that reflect corporate actions are public and certified. They include valuable data points, such as the owner’s name, place of business, and FEIN tax ID number.

“These are data points that every state wants to see, contained in a single document that is a certified public record and reliable under the evidence rules and reliable by common sense,” said Thomas Palmer, partner with Thompson Hine, LLP. “There's a trend in some states to get away from using public information, but I believe that this public information is exactly what the state should rely upon and find to be reliable because claimant reps can go to the secretary of state websites, double-check the information and confirm it.”

The preponderance of evidence standard considers all available information together, rather than each single document individually. For example, information provided in a LexisNexis report can corroborate or verify other evidence, lending it credibility and allowing the states to pay claims without fear of fraud.

Sometimes, states exceed the preponderance of evidence standard, making it too difficult for claimants to successfully complete their claims. Examples include:

Requiring “beyond a doubt” proof.
Demanding original uncashed checks.
Requiring proof of reported address despite other reliable evidence.
Rejecting public domain documents, despite court acceptance.
Denying claims even when submitted by an owner with a unique, legally protected business name where no other claimant could reasonably exist.

“Exceeding the preponderance standard discourages claims from being filed or continued when these types of demands are put on claimants, and they can’t achieve it,” said David Knott, founder and managing director of United Asset Recovery. “They just give up eventually.”

Fair evidence review, when applied using the preponderance standard, results in higher return rates, fulfills administrators’ legal obligations, avoids penalizing legitimate owners and builds trust in government.

“The preponderant standard is about reasonable flexibility,” said Warren. “If the legal standard is more likely than not, then evidence policies should reflect real-world records and realities. Higher burdens, like clear and convincing standards, that are creeping in through practice can suppress legitimate recoveries and run contrary to the core principle of unclaimed property, which is to reunite the rightful owner with their unclaimed property.”

UPPO members can view a complete recording of the Evidence Standards webinar in the On-Demand Webinar Library.

Unclaimed Property News Roundup

Fri, 17 Oct 2025 18:55:00 GMT

Unclaimed property often makes news headlines. UPPO occasionally provides a snapshot of some of the more interesting and entertaining stories receiving coverage from local and national media outlets recently.

On Oct. 16, 2025, WMAR in Baltimore reported on the Maryland Comptroller’s Office launching a new unclaimed property website. Like many other states, Maryland now uses the KAPS platform.

On Oct. 14, 2025, Yahoo Finance and several crypto-related news sites published stories about California Gov. Gavin Newsom signing S.B. 822. Under the new law, digital currency will not be liquidated before escheatment to the state when such accounts have been inactive for more than three years.

On Oct. 13, 2025, Fox 23 News reported on a Better Business Bureau of Eastern Oklahoma warning about fraudulent unclaimed property notices that require consumers to pay a $50 processing fee to receive their funds. Unfortunately for the unwitting respondents of such notices, they receive no reimbursement of their unclaimed property by the scammers who received the $50 fee.

On Aug. 26, 2025, Arizona Capitol Times reported on an appeals court decision allowing for the continuation of litigation over notification requirements to owners regarding unclaimed property. The plaintiffs argue that the state simply publishing property owners’ names on an unclaimed property website is inadequate and deprives them of their right to due process.

Arkansas, Colorado and Maine Advocacy Reflect GRAC’s Progress

Thu, 9 Oct 2025 18:54:10 GMT

UPPO’s Government Relations and Advocacy Committee (GRAC) has a long history of leading the association’s critical advocacy initiatives. The committee has made an ongoing commitment to continually refining and improving its processes to get the most effective results possible for the unclaimed property community. Recent work in Arkansas, Colorado and Maine demonstrates the committee’s effectiveness at building relationships with the states and helping ensure the organization’s positions receive consideration.

Arkansas

Over the summer, GRAC identified several concerns related to proposed changes to the state’s administrative rules. The potentially problematic areas noted cover provisions regarding:

Due diligence.
Property escheatment.
The form in which property is reported.
The securities pre-approval requirement.
Oil and gas.
Burden of proof.

Based on GRAC’s findings, UPPO contacted Arkansas officials, who were receptive to the association’s suggestions. Subsequent meetings between state officials and UPPO representatives included meaningful discussion of the issues and indications that Arkansas is open to UPPO’s proposed changes, which are currently under review.

Colorado

In Colorado, H.B. 25-1224 takes steps to simplify the presumption of abandonment requirements for tax-deferred retirement accounts. Unfortunately, the bill’s language introduces ambiguity and could adversely affect individual retirement account owners.

Section 4 of the bill modifies when tax-deferred retirement accounts are presumed abandoned under Colorado’s unclaimed property law. Specifically, the amendments state an IRA is presumed abandoned three years after the account “becomes payable or distributable” if the owner has not accepted the distribution, corresponded in writing, or otherwise indicated an interest in the account.

IRAs require distribution based on various criteria under the Internal Revenue Code. The Required Minimum Distribution is a specific deadline. Tax-deferred retirement accounts, such as traditional IRAs, do not require withdrawals until the owner reaches the RMD age. There are also special rules in federal tax law requiring beneficiaries to take distributions within a certain number of years after an IRA owner dies, and the timing of the required distribution depends on whether the owner died before or after the RMD age.

Upon GRAC’s review of H.B. 25-1224 and identification of its likely effects, UPPO asked Colorado for policy guidance published with clarifying language confirming that the dormancy period begins to run when the owner (or a beneficiary after the owner’s death) is required to take such distributions, because that is when the IRA proceeds become payable or distributable. This interpretation would ensure regulatory consistency with other states’ unclaimed property laws, maintain consistency with federal law, avoid tax harm to investors and preserve the intent of the retirement investment in a manner consistent with federal tax policy and established industry operations and practices.

Colorado officials were receptive to UPPO’s request and have moved it to legal review and are expected to publish requested guidance.

Maine

When GRAC identified significant unintended consequences of H.B. 1313 and L.D. 1969, UPPO notified state officials of its concerns and requested the state study the issues further before proceeding with the bills. The two biggest issues identified by GRAC are:

H.B. 1313 would disrupt Maine investors’ expectations by presuming their investments are abandoned after only three years of account inactivity. If the legislation passes, buy-and-hold investors would be at serious risk of having their investments prematurely escheated and liquidated.
H.B. 1313 would also require holders to liquidate and escheat virtual currency after five years of inactivity. Requiring pre-escheat liquidation of virtual currency creates an unnecessary risk of loss to owners, who would not be entitled to compensation for post-liquidation increases in the value of the virtual currency.

UPPO’s request resulted in a meeting with Maine’s unclaimed property administrator to discuss these concerns. The state was receptive to UPPO’s suggestions and intends to amend the proposed legislation.

These three recent examples of GRAC’s work demonstrate the importance of the committee’s work. They also reflect a shift that has taken place in the relationship between UPPO and the states. More than ever, many states recognize that when UPPO raises red flags about potential issues with proposed regulations and legislation, they are worthy of review and consideration.

State officials increasingly welcome UPPO’s feedback and are eager to engage in discussions and make adjustments to reduce potential conflicts that are likely to arise when changes become effective.

Thank you to GRAC members for their commitment to advocating on behalf of the unclaimed property community and contributing their time and expertise to encourage a fair compliance environment.

What is Delaware’s CHRVO Program?

Thu, 9 Oct 2025 23:50:57 GMT

Delaware’s Office of Unclaimed Property has introduced a Complex Holder Reimbursement Verified Organization (CHRVO) program. The program is intended to streamline the processing of holder reimbursement claims by consolidating multiple reimbursement requests into a single, annual claim. Rather than submitting individual claims throughout the year, holders participating in CHRVO can submit all of their reimbursement requests as a single claim for the year between Aug. 1 and Aug. 31.

This program does not replace the claim reimbursement process that’s already in place. It is intended for claimants who average 35 or more claims annually. As a benefit of participating, CHRVO claims are given priority payment status of 90 days. This differs from the standard process, under which submitted claims are added to a queue and paid out on a first-in, first-out basis rather than within a 90-day reimbursement window.

Holders that are interested in CHRVO can request information by emailing escheatholderreimbursements@delaware.gov. The Office of Unclaimed Property will respond with an application form, claim form and template for listing all properties. Upon submission of completed claim and property forms in August, the office will create and process the claim, including all listed properties.

September 2025 President's Message

Mon, 29 Sep 2025 20:09:01 GMT

It has been a busy and productive summer, and I’m pleased to update you on just a couple of UPPO’s latest initiatives – the Operational Compliance Task Force (now a full-standing Committee) and our updated Strategic Plan.

The Operational Compliance Committee was formed to work hand in hand with our members, the Government Relations and Advocacy Committee (GRAC) and the states to identify critical operational issues that are needed to effectuate compliance. As the Committee has quickly ramped up, it has begun establishing its priorities to ensure they align with members’ concerns. The Committee is focusing on:

Challenges encountered with report delivery, remittance and payment methods.
Awareness regarding changes to reporting, remitting and transfers of securities.
Processing of holder reimbursement claims.
Lack of clear guidance on due diligence and/or reporting procedures.
Accelerated (or extended) dormancy triggers.

Some of the Committee’s early work is already proving useful. They have revamped the association’s biannual state administrator survey, used to provide information for our Fall and Spring Unclaimed Property Reporting Guides. The updated survey resulted in participating states providing more detailed information about their states’ reporting requirements. These details are included in the newly published 2025 Fall Unclaimed Property Reporting Guide. Further, member have participated in conversations with states on proposed regulation change and their operational challenges and are working with GRAC to provide operational insights on other proposed legislative and regulatory changes.

In August, the UPPO Board met at the association’s office in Minneapolis to review and update the strategic plan, which serves as the roadmap for our work. This intensive exercise included a thoughtful discussion of our community’s needs and how UPPO can best serve its members. The resulting goals and objectives include:

Education: Provide unclaimed property educational resources.
Advocacy: Advocate for consumer and compliance-friendly laws, regulations and administrative guidance.
Membership: Provide membership value.
State and Other Jurisdictional Relations: Expand constructive relationships with reporting jurisdictions.
Building Visibility: Leverage public relations/marketing/partnerships.

These high-level goals and objectives are now providing the foundation for development of the tasks that will ultimately ensure UPPO continues to serve as the foremost resource for unclaimed property professionals. In the coming months, the board will work to develop a set of tactics that will work towards achieving these goals.

Fortunately, UPPO is filled with passionate, talented professionals who consistently step up to share that passion and talent for the greater good of our organization. With your continued support and assistance, the association will continue to grow, improve and support our shared needs.

Lastly, I encourage you to make plans to join UPPO next March in San Antonio, Texas, for the 2025 Annual Conference! Please review the action-packed agenda and register early to lock in your spot at the best available rate. Whether you’ve attended many previous conferences or will be a first-timer, I look forward to seeing you there.

DEIB Spotlight: Hearing Impairment in the Workplace

Fri, 19 Sep 2025 15:45:40 GMT

DEIB Spotlight is a UPPO DEIB Committee initiative that celebrates diversity by highlighting topics and members that help make UPPO a welcoming association for all unclaimed property professionals.

September is National Deaf Awareness Month, and Sept. 23 is the International Day of Sign Languages. With these events in mind, this is the ideal time to consider ways to make the workplace more inclusive for people with hearing impairment.

More than 50 million Americans – nearly one in seven – have some degree of hearing loss, according to the Hearing Loss Association of America, making it the third most common chronic physical condition in the nation. While not everyone suffering from hearing loss requires accommodations, many do.

Employers are required to provide accommodations in accordance with the Americans with Disabilities Act. Beyond what is legally required, implementing practical strategies encourages greater equity and production, makes the company more appealing to a broader pool of potential employees and fosters a better organizational culture for current employees.

Following are several tactics to make workplaces more inclusive for people with hearing impairment.

Provide communication accommodations

Offer sign language interpreters or real-time captioning in meetings, events and training sessions.
Use assistive listening devices and hearing aid-compatible systems.
Provide written summaries or agendas before meetings.

Optimize physical workspaces

Reduce background noise using carpeting, curtains and sound panels.
Offer quiet rooms or pods for focused work.
Ensure lighting is good, allowing for easier lip reading and visual cues.

Make digital and written materials accessible

Make materials available via video with accurate captions.
Ensure audio communications also have text alternatives.
Use accessible formats for internal documentation.

Offer training and raise awareness

Include hearing-related topics in sensitivity training for all staff.
Share communication best practices: face your audience, don’t cover your mouth, rephrase rather than repeat, etc.
Provide optional sign language training.

Update policies and establish clear procedures

Establish a formal accommodation request process.
Review emergency systems, such as alarms and alerts, to incorporate visual or vibrational signals.

Offer flexible working arrangements

Allow remote work or hybrid options, particularly for noisy or distracting tasks.
Provide flexible schedules for medical/audiology appointments.

Learning more about the challenges faced by those who are deaf or have limited hearing and taking steps to create a more welcoming workplace is good business. It makes a more positive work environment and breaks down barriers that may limit productivity and collaboration. Ensuring your workplace is conducive to those with hearing challenges promotes a greater sense of belonging and creates a more welcoming environment for employees and potential employees.

2025 Fall Unclaimed Reporting Guide (Part IV)

Mon, 15 Sep 2025 14:58:46 GMT

Fall reporting season is upon us yet again. 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 has been 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: Oct. 31, 2025
Extensions: Extensions may be requested by email before the report due date.
Contact: unclaimed@sto.sc.govor (803) 737-4771
South Carolina holder resources
Notes from UPPO’s state administrator survey:

An online portal is acceptable for capturing responses to due diligence letters or pre-presumption outreach.
State does not require securities dividends to be totaled by owner and reported as a lump sum amount for reporting.
State requires this form to be included with report filing only with US Savings Bond reporting; it is not required when reporting any other property types.
State does not accept electronic signatures.
See our website for communication requirements related to securities.
Reports must be submitted electronically via the state’s website.
State's system does not have any formatting requirements that might cause a file to be rejected.
State's systems does not accept a test file.
State does not require online payment at the time of electronic filing. Payment is due by Nov. 1.
State does not require holder number.
Report file formats accepted: TXT (preferred).
To request an extension to the November 1 reporting deadline, email unclaimed@sto.sc.gov. There should be extenuating circumstances for a holder to qualify for an extension.
Remittance options: ACH credit, ACH debit (preferred), wire, credit card. Email to request wire instructions.
Credit card payments are provided as a convenience. The payment portal will accept payment by Mastercard, Visa or Discover. Please note, a service fee will be applied to all credit card payments. This fee is charged by the service provider and is not paid to the state.
It is important to review your records every year to determine if you have any unclaimed property to report. If after reviewing your records, you do not identify any property due to the State of South Carolina, please submit a negative report on the state website.

South Dakota
Report due: Oct. 31, 2025
Extensions: Extensions may be requested in writing before the report due date.
Contact: holders@sdtreasurer.govor (605) 773-3379
South Dakota holder resources
Notes from UPPO’s state administrator survey:

Holder reporting manual/handbook available.
An online portal is acceptable for capturing responses to due diligence letters or pre-presumption outreach.
State does not require securities dividends to be totaled by owner and reported as a lump sum amount for reporting.
State does not require a signed cover sheet or other documentation to be included with the annual report.
Please notify the state of ACH/Wire transaction, including date, holder name and FEIN and amount of the transaction. Breakout of amounts and FEIN if multiple reports are being paid on one transaction.
State's system does not have any formatting requirements that might cause a file to be rejected.
State's systems does not accept a test file.
State does not require online payment at the time of electronic filing. Payment is required within 30 days of reporting.
State does not require holder number.
Report submission formats accepted: electronic upload (preferred).
Report file formats accepted: TXT (preferred).
Extensions granted for multiple consecutive years can possibly disqualify a holder.
Remittance options: ACH credit (preferred), check, wire. Email to request wire instructions.
Information ACH or Wire money to South Dakota Unclaimed Property Division: First Premier Bank - name 601 S. Minnesota, Sioux Falls, SD 57101 State of SD Treasurer - account name Checking â€“ account type 1701269763 - account number 091408598 - ABA routing number Please indicate it as Unclaimed Property (UCP) in the ACH Description field (Entry Detail Record). Include "UCP" addedum information. For wire transfers indicate Unclaimed Property (UCP) in the description.
We have added clarification of virtual currency this July 1. SDCL 43-41B-45.

Tennessee
Report due: Oct. 31, 2025
Extensions: Extensions may be requested.
Contact: ucp.holders@tn.gov or (615) 253-5362
Tennessee holder resources
Notes from UPPO’s state administrator survey:

Remittance options: ACH credit, ACH debit (preferred), wire, credit card. ACH credit instructions. Wire instructions. Additional payment instructions.
$2.29 will be charged for using card.
State requires online payment at the time of electronic filing.
State allows test payments.

Utah
Report due: Nov. 3, 2025
Extensions: Extensions may be requested in writing by Oct. 1.
Contact: holders@utah.gov or (801) 715-3300
Utah holder resources

Virgin Islands
Report due: Oct. 31, 2025
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: Oct. 31, 2025
Extensions: Extensions may be requested.
Contact: report.remit@trs.virginia.gov or (804) 225-2393
Virginia holder resources

Washington
Report due: Oct. 31, 2025
Extensions: Extensions may be requested by email before the report due date.
Contact: WAUCPHolders@dor.wa.gov or (360) 534-1502
Washington holder resources
Notes from UPPO’s state administrator survey:

West Virginia
Report due: Oct. 31, 2024
Extensions: Extensions may be requested.
Contact: Eholder-Support@wvsto.com or (800) 642-8687
West Virginia holder resources

Wisconsin
Report due: Nov. 3, 2025
Extensions: Extensions may be requested during September and October through My Tax Account.
Contact: DORWIHolderReports@wisconsin.gov or (608) 264-4594
Wisconsin holder resources
Notes from UPPO’s state administrator survey:

Holder reporting manual/handbook available.
State does not have a pre-presumption outreach requirement.
State does not require securities dividends to be totaled by owner and reported as a lump sum amount for reporting.
State does not require a signed cover sheet to be included with the annual report.
Shares must be cleared by Avenu prior to being reported to the state. Do not report worthless or restricted shares.
Report must be submitted as a .txt file. Reports with multiple holders, safekeeping, and or shares should use this link to upload their reports.
State's systems does not accept a test file.
State does not require online payment at the time of electronic filing.
State does not require holder number.
Remittance options: electronic upload (preferred).
Report file formats accepted: TXT (preferred).
Habitual extension requestors may be denied.
Remittance options: ACH debit (preferred), check. Instructions. Reversed, rejected or NSF payments will incur a penalty.
Payment is required by Nov. 1.
You must have a holder account before you can make an ACH Debit payment. If you have not previously filed a holder report with the department, you will need to wait 24 hours after filing your first report before initiating your ACH Debit payment.

Wyoming
Report due: Oct. 31, 2025
Extensions: Extensions may be requested .
Contact: upreports@wyo.gov or (307) 777-5590
Wyoming holder resources
Notes from UPPO’s state administrator survey:

State does not have a pre-presumption outreach requirement.
An online portal is not acceptable for capturing responses to due diligence letters or pre-presumption outreach.
State requires a signed cover sheet with the annual report filing.
State accepts electronic signatures.
State's system does not have any formatting requirements that might cause a file to be rejected.
State's systems does not accept a test file.
State does not require online payment at the time of electronic filing.
State does not require holder number.
Report submission formats accepted: electronic upload (preferred).
Extension requests may be denied if holder has history or repeatedly seeking an extension.
Remittance options: ACH debit, check. Instructions.
Payment is due by Nov. 1.
$1 fee for ACH payment.

2025 Fall Unclaimed Reporting Guide (Part III)

Thu, 11 Sep 2025 15:24:47 GMT

Fall reporting season is upon us yet again. 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 over the next two weeks:
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: Oct. 31, 2025
Extensions: No details provided

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

Missouri

Report due: Oct. 31, 2025
Extensions: Extensions may be requested before the reporting due date.

Contact: Contact form or (573) 751-0123
Missouri holder resources
Notes from UPPO’s state administrator survey:

All types of property are subject to the due diligence requirement.
An online portal is acceptable for capturing responses to due diligence letters or pre-presumption outreach.
State does not require securities dividends to be totaled by owner and reported as a lump sum amount for reporting.
State requires a signed cover sheet with annual report.
State accepts electronic signatures. State will waive cover sheet notary requirement for remote employees.
State prefers that holders upload their reports through its web portal.
If reporting gift certificates, the reported and remitted amounts must be identical. The deduction should only be reflected in the payment from the holder.
State’s system does accept a test file. Load the file then alert them that it may need to be deleted.
State expects payments “more or less at the time of filing.” A gap of a few days is al-lowed.
State does require holder number.
Report submission formats accepted: electronic upload (preferred), flash drive, paper (on-ly if the report includes fewer than 50 properties).
Report file formats accepted: HDE (preferred).
Remittance options: ACH credit, ACH debit (only through web portal), check, wire. Contact the state for electronic payment instructions.
Test payments allowed. State needs to be notified by the holder which payments should be considered tests, so that they may deal with them accordingly.

Montana

Report due: Oct. 31, 2025
Extensions: Extensions may be requested before the reporting date and will be considered on a case-by-case basis.

Contact: UnclaimedProperty@mt.gov or (406) 444-6900
Montana holder resources
Notes from UPPO’s state administrator survey:

Holder reporting manual/handbook available.
State does not have a pre-presumption outreach requirement.
An online portal is not acceptable for capturing responses to due diligence letters or pre-presumption outreach.
State does not require securities dividends to be totaled by owner and reported as a lump sum amount for reporting.
State does not require a signed cover sheet or other documentation with annual report.
Please visit mycash.mt.gov for any holder reporting and payment information.
State system requires report format to follow NAUPA guidelines.
State system accepts test files. Set up with e-services department.
Holder number is required at time of filing (use EIN).
Report submission formats accepted: electronic upload (preferred), email, paper, manual entry (only if the report includes 10 or fewer properties).
Please see state guidelines for acceptable file formats.
Pre-payment requirement: Estimated amount due by reporting deadline.
Remittance options: ACH credit (preferred), ACH debit check, wire. Payment details at mycash.mt.gov – see reporting guidelines for holders. Subject to credit card fees.
Registration is required for online payment.
No test payments allowed.

Nebraska

Report due: Oct. 31, 2025
Extensions: Extensions may be requested.

Contact: NST.UPHolderReporting@Nebraska.gov or (877) 572-9688
Nebraska holder resources

Nevada

Report due: Oct. 31, 2025
Extensions: Extensions may be requested.

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

New Hampshire

Report due: Oct. 31, 2025
Extensions: Extensions may be requested in writing before the reporting deadline.

Contact: unclaimedproperty@treasury.nh.gov or (603) 271-2619
New Hampshire holder resources

New Jersey

Report due: Oct. 31, 2025
Extensions: Extensions may be requested.

Contact: unclaimedreports@treas.nj.gov or (609) 292-9200
New Jersey holder resources

New Mexico

Report due: Oct. 31, 2025
Extensions: Extensions may be requested.

Contact: unclaimed.property@tax.nm.gov or (505) 827-0866
New Mexico holder resources
Notes from UPPO's state administrator survey:

Holder reporting manual/handbook available.
State does not have a pre-presumption outreach requirement.
An online portal is acceptable for capturing responses to due diligence letters or pre-presumption outreach.
State requires securities dividends to be totaled by owner and reported as a lump sum amount for reporting.
State requires a signed cover sheet to be included with annual report.
State accepts electronic signatures. State will waive cover sheet notary requirement for remote employees.
State’s system accepts test file. Email unclaimed.Property@tax.nm.gov.
State does not require holder number.
Report submission formats accepted: electronic upload (preferred)
Report file formats accepted: CSV (preferred), HDE, TXT
The holder, upon receipt of an extension, may make an interim payment on the amount the holder estimates will ultimately be due, which terminates the accrual of additional interest on the amount paid.
Remittance options: ACH debit, check(preferred). Email to request wire instructions.
No test payments allowed.

North Dakota

Report due: Oct. 31, 2025
Extensions: Extensions may be requested in writing and will be considered on a case-by-case basis.

Contact: unclaimed@nd.gov or (701) 328-2800
North Dakota holder resources
Notes from UPPO’s state administrator survey:

Holder reporting manual/handbook available.
State does not have a pre-presumption outreach requirement.
An online portal is acceptable for capturing responses to due diligence letters or pre-presumption outreach.
State does not require securities dividends to be totaled by owner and reported as a lump sum amount for reporting.
State does not require a signed cover sheet or other documentation with annual report.
State's system does not have any formatting requirements that might cause a file to be rejected.
State's systems does not accept a test file.
State does not require holder number.
Report submission formats accepted: electronic upload (preferred)
Report file formats accepted: HDE (preferred), HRS
Remittance options: ACH credit, ACH debit (preferred), wire. Email to request wire instruc-tions.
Online payment is due at time of online filing. Instructions.
If a holder initiates an ACH credit or wire, the associated fees are theirs.
No test payments allowed.

Ohio

Report due: Oct. 31, 2025
Extensions: Extensions may be requested.

Contact: UNFDCompliance@com.ohio.gov or (877) 644-6823
Ohio holder resources

Oklahoma

Report due: Oct. 31, 2025
Extensions: Extensions may be requested in writing on company letterhead before the report due date.

Contact: holderinfo@treasurer.ok.gov or (405) 521-2055
Oklahoma holder resources

Oregon

Report due: Oct. 31, 2025
Extensions: Extensions may be requested.

Contact: holder@ost.state.or.us or (503) 986-5290
Oregon holder resources
Notes from UPPO’s state administrator survey:

Holder reporting manual/handbook available.
State does not have a pre-presumption outreach requirement.
An online portal is acceptable for capturing responses to due diligence letters or pre-presumption outreach, as long as you capture all requirements of OAR 175-145-0015. The state may reach out asking for evidence of due diligence.
State does not require securities dividends to be totaled by owner and reported as a lump sum amount for reporting.
State does not require a signed cover sheet or other documentation with annual report.
All reports must be submitted electronically and in the requested format. For most reports, no other documentation is required to be submitted with the report.
All files must be in the NAUPA II format.
State's systems does accept a test file. Holder must reach out to the Oregon staff to accommodate this.
Payment is due at the time of filing, however, holders are not required to pay online.
State does not require holder number.
Report submission formats accepted: CD, electronic upload (preferred), flash drive.
Report file formats accepted: TXT (preferred).
State does not have a prepayment requirement.
Remittance options: ACH credit (preferred), ACH debit, check, wire. Email to request wire instructions.
Holders may be subject to fees charged by their financial institutions.
Due to the outcomes of the 2025 legislative session, there will be changes to the 2026 report year. State will send out notices to active holders.

Rhode Island

Report due: Oct. 31, 2025
Extensions: Extensions may be requested up to 30 days before the deadline.

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.

2025 Fall Unclaimed Reporting Guide (Part II)

Tue, 9 Sep 2025 16:55:30 GMT

Fall reporting season is upon us yet again. 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 over the next two weeks:

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: Oct. 31, 2025
Extensions: Extensions may be requested before the report due date.

Contact: UCPBusinessQuestions@sto.idaho.gov or (208) 332-2971
Idaho holder resources

Indiana

Report due: Oct. 1, 2025
Extensions: Extensions may be requested at least 30 days before the reporting due date. Please fill out an extension request form. The request must be accompanied by a detailed explanation on corporate letterhead that outlines the reason for seeking approval.

Contact: updholder@atg.in.gov, (317) 234-9768
Indiana holder resources
Notes from UPPO’s state administrator survey:

Holder reporting manual/handbook available.
State requires a Report Submission Summary Report with annual report filing. Please print and attach the report submission summary to the check, then mail it to our office. Additionally, print a copy of the report submission summary for your records.
State accepts electronic signatures.
Holder reports must contain all owner information, if known. Reporting this infor-mation is critical to the claiming process and reduces the chances that the owner will need to contact the holder to request documentation to support their claim.
State's systems does not accept a test file.
Holders can make an online payment after submitting their report, as the state’s sys-tem will guide them through the process. Alternatively, they can send a check made out to the State of Indiana and attach it to the report submission summary.
State does not require holder number.
Report submission formats accepted: Electronic upload.
Report file formats accepted: TXT.
Remittance options: ACH credit (preferred), check, wire. Email to request wire instruc-tions. Make checks payable to "State of Indiana" or pay online after submission.
The Office of the Attorney General accepts Visa, MasterCard, Discover, and American Express with a convenience fee of 2.25% (minimum fee of $1.00) for both credit card and debit card payments. Also, eCheck payments are accepted with a convenience fee of $1.00. This convenience fee is nonrefundable.

Iowa

Report due: Oct. 31, 2025
Extensions: Extensions may be requested before the reporting due date.

Contact: upreport@tos.iowa.gov or (515) 281-7546
Iowa holder resources
Notes from UPPO’s state administrator survey:

Holder reporting manual/handbook available.
State does not have a pre-presumption outreach requirement.
State does not require securities dividends to be totaled by owner and reported as a lump sum amount for reporting.
State does not require a cover sheet or other form to be submitted with annual report.
Formatting requirements: SSN is required for bank accounts and wages. Withholdings is required for IRA accounts.
State's systems does not accept a test file.
State does not require online payment at the time of electronic filing.
State does not require holder number.
Report submission formats accepted: Electronic upload (preferred).
Report file formats accepted: TXT (preferred), HRS, RPT.
Payment instructions.

Kansas

Report due: Oct. 31, 2025
Extensions: Extensions may be requested. Multiple extension requests may not be approved.

Contact: KSHolder@treasurer.ks.gov or (785) 291-3173
Kansas holder resources
Notes from UPPO’s state administrator survey:

State does not have a pre-presumption outreach requirement.
State does not require securities dividends to be totaled by owner and reported as a lump sum amount for reporting.
State does not require a cover sheet or other form to be submitted with annual report.
If a report is being paid for via wire/ACH credit we ask for an email the day of payment with the amount to ksholder@treasurer.ks.gov.
State's system does not have any formatting requirements that might cause a file to be rejected.
State's systems does accept a test file. Please notify ksholder@treasurer.ks.gov that you are submitting a test file.
State does not require online payment at the time of electronic filing.
State does not require holder number.
Report submission formats accepted: CD, electronic upload (preferred), flash drive, paper.
Report file formats accepted: PDF, TXT (preferred).
Remittance options: ACH credit, ACH debit (preferred), check, wire. Instructions.
Payment is due as soon as possible following report filing.
Please notify ksholder@treasurer.ks.gov if you are doing a test payment.

Kentucky

Report due: Oct. 31, 2025
Extensions: Extensions may be requested

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

Louisiana

Report due: Oct. 31, 2025
Extensions: Extensions may be requested before the report due date.

Contact: (888) 925-4127
Louisiana holder resources

Maine

Report due: Oct. 31, 2025
Extensions: Extensions may be requested up to 30 days before the report due date. Incomplete forms, including missing estimated amount and reason for extension will be rejected for completion.

Contact: up.holderinquiry@maine.gov or (207) 624-7463
Maine holder resources
Notes from UPPO’s state administrator survey:

Holder reporting manual/handbook available.
State does not have a pre-presumption outreach requirement.
An online portal is acceptable for capturing responses to due diligence letters or pre-presumption outreach.
State does not require securities dividends to be totaled by owner and reported as a lump sum amount for reporting.
State does not require a cover sheet or other form to be submitted with annual report.
Required documentation/communication: Online upload through the state's website of holder report in NAUPA format and payment sent by ACH Debit (PayMaine) or check mailed with confirmation of uploading the report.
Report file must follow NAUPA II reporting format.
State's systems does not accept a test file.
Please submit payment within a week of uploading a report to ensure both items will be identified for reconciliation.
State does not require holder number.
Report submission formats accepted: electronic upload (preferred).
Report file formats accepted: TXT (preferred).
Prepayment requirement: Estimated payment is due by November 1st for an extension request. Payment can be made by ACH Debit or mailed checks following the payment instruction on the Unclaimed Property website and in the reporting manual.
Remittance options: ACH debit (preferred), check.
Payment is required at the time of online filing.
Fees are only assessed by law for returned payments. Please make sure the ACH Company ID is provided to your bank if the account holds a debit block.
No gift obligation reporting to Maine.

Maryland

Report due: Oct. 31, 2025
Extensions: Extensions may be requested in writing on company letterhead before reporting deadline. Requests will be considered on a case-by-case basis.

Contact: upholder@marylandtaxes.gov or (410) 767-1700
Maryland holder resources
Notes from UPPO’s state administrator survey:

Holder reporting manual/handbook available.
In September we will have a new state website and updated Holder Reporting Manual as well as links.
Pre-presumption outreach requirement: All accounts that are over aggregate. Starting Oct. 1, 2025, that will be for all accounts that are over $50, stock-related, and safe-deposit-box-related.
An online portal is acceptable for capturing responses to due diligence letters or pre-presumption outreach.
State does not require securities dividends to be totaled by owner and reported as a lump sum amount for reporting.
State requires a signed cover sheet and payment or proof of payment with annual report.
State accepts electronic signatures. We are a report and remit state so it must be done at the same time.
State's system does not have any formatting requirements that might cause a file to be rejected.
State's systems does not accept a test file.
State does require holder number.
Report submission formats accepted: CD, electronic upload (preferred), email, flash drive, paper.
Report file formats accepted: TXT (preferred).
Prepayment requirement details.
Remittance options: ACH credit, ACH debit (preferred), check, wire. Instructions. Fees may apply to ACH credit payments.
Payment is required at the time of online filing.

Massachusetts

Report due: Oct. 31, 2025
Extensions: Extensions may be requested

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

Minnesota

Report due: Oct. 31, 2025
Extensions: Extensions may be requested up to 30 days before the reporting deadline.

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

2025 Fall Unclaimed Reporting Guide (Part I)

Wed, 3 Sep 2025 18:28:36 GMT

Fall reporting season is upon us yet again. 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 over the next two weeks:
Part 1 covers Alabama through Hawaii.
Part 2 will cover Idaho through Minnesota
Part 3 will cover Mississippi through Rhode Island.
Part 4 will cover South Carolina through Wyoming.

Alabama

Report due: Oct. 31, 2025
Extensions: Extensions may be requested in writing. Include reason for extension request and length of time needed.

Contact: unclaimed@treasury.alabama.gov or (334) 242-9614 or (888) 844-8400
Alabama holder resources

Alaska

Report due: Oct. 31, 2025
Extensions: Extensions may be requested.

Contact: ucpholder@alaska.gov or (844) 252-2741
Alaska holder resources

Arizona

Report due: Oct. 31, 2025
Extensions: Extensions will be considered on a case-by-case basis and may be requested by fax or email. Include company name, holder number or company FEIN, reason for extension and length of extension requested.

Contact: ReportingUnclaimedProperty@azdor.gov or (602) 716-6031
Arizona holder resources

Notes from UPPO’s state administrator survey:

Holder reporting manual/handbook available.
State is working on webpages relating to cryptocurrency reporting.
State does not have a pre-presumption outreach requirement.
State does not require securities dividends to be totaled by owner and reported as a lump sum amount for reporting.
State requires a cover sheet and the 650A schedule if 10 properties or less, or the NAUPA file.
State accepts electronic signatures.
State's system does not have any formatting requirements that might cause a file to be rejected.
State's systems does not accept a test file.
State does not require online payment at the time of electronic filing.
State does not require holder number.
Report submission formats accepted: CD, email (preferred), flash drive, paper
Report file formats accepted: HDE (preferred), TXT
Remittance options: check, wire (preferred). Email to request wire instructions.
Holder's bank may charge a wire fee.
State is making two changes this year: 1. Holders in custody of reported mutual funds should pay any accrued dividends and capital gains as cash, not reinvested. 2. With the signing of HB 2749, Holders are now required to report cryptocurrency in its native form.

Arkansas

Report due: Oct. 31, 2025
Extensions: Extensions may be requested by email up to one day before the reporting deadline.

Contact: holders@auditor.ar.gov or (501) 682-6000
Arkansas holder resources

California

Report due: Oct. 31, 2025, for Holder Notice Reports
Extensions: Extensions may be requestedno later than 30 days before the due date.

Contact: updholderoutreach@sco.ca.gov or (916) 464-6088
California holder resources

Colorado

Report due: Oct. 31, 2025
Extensions: Extensions may be requested no later than 30 days before the due date.

Contact: Holders@state.co.us or (800) 825-2111
Colorado holder resources

District of Columbia

Report due: Oct. 31, 2025
Extensions: Extensions may be requested by email, fax or mail.

Contact: Holders.UCP@dc.gov or (202) 442-8181
District of Columbia holder resources

Georgia

Report due:Oct. 31, 2025
Extensions: Extensions may be requested by email. Include EIN, business name, reason for extension and expected filing date.

Contact: ucp.reporting@dor.ga.gov or (855) 329-9863
Georgia holder resources

Hawaii

Report due: Oct. 31, 2025
Extensions: For extension information, contact the state's unclaimed property office.

Contact: budgetandfinance@hawaii.gov or (808) 586-1589
Hawaii 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.

Revisiting California’s Voluntary Compliance Program Webinar Follow-Up Questions

Wed, 27 Aug 2025 23:50:55 GMT

UPPO’s recent Revisiting California’s Voluntary Compliance Program webinar provided an overview of the VCP, the steps required to obtain an interest waiver and lessons learned since the program’s implementation. Because limited time prevented presenters from responding to some of the participant questions during the webinar, they kindly agreed to respond for publication on UPPO’s Unclaimed Property Focus blog. UPPO members can view the webinar via the On-Demand Webinars page.

Does the state have any guidance for addressing requests for reissue based on the pre-escheatment process, where the requests appear to be fraudulent? For example, we have received a request for funds to be reissued to an individual when the checks were issued to a large company.
A holder that is contacted by a potential property owner or claimant should employ reasonable efforts to validate that the person or business is the rightful owner who is entitled to the funds. As an example, a holder can take steps to validate the person in a similar manner as would be done to validate a caller to a customer service center by confirming proper responses from the individual against records on hand used to grant access or be able to speak to a person about their account or activity. For instance, what is their account password, PIN or other similar customer-created code, SSN, address, account activity, last order info, mother’s maiden name or other similar unique records you may have.

In this instance, on a request for funds to be reissued to an individual when the checks were issued to a large company, steps can be taken to support why such a change should be made. Potential records to support this could be a purchase agreement or a record of dissolution filed with a government agency, such as the secretary of state’s office.

The state also encourages a holder to do its own due diligence to validate the claimant and the appropriateness of making the payment. If a holder is ultimately not comfortable with the support provided to validate a payment being made, the state ultimately encourages a holder to defer a payment and instead include the property on the final Remit Report and remit the funds to the state, so the claimant will then need to file a satisfactory and fully supported claim with the state.

After filing the notice report, California sends a letter. How is the holder notified if a vendor responds to the California letter?
The State Controller’s Office does send notices, as required, to all owners of property that will be transferred to the state. These notices are sent out before the property is to be transferred, giving owners an opportunity to retrieve the property directly from the holder.

The pre-escheat letters direct property owners to contact the holder directly. Contact information is provided in the letter as was reported to the state by the holder in the Notice Report. These letters do not direct the owner to respond to the state or contact us. So, if the process is functioning properly, the holder would be aware of a response by virtue of a direct response from the owner themselves. If the state does receive an inquiry from a property owner about the letter sent out, we will provide them with the holder’s contact information and let them know they should contact the holder directly.

Ask the Experts Webinar Follow-Up Questions

Thu, 21 Aug 2025 12:15:15 GMT

UPPO’s recent Ask the Experts webinar featured a panel of unclaimed property veterans responding to participant-submitted questions about compliance best practices, reporting requirements and other unclaimed property topics. Because limited time prevented presenters from responding to some of the participant questions during the webinar, they kindly agreed to respond for publication on UPPO’s Unclaimed Property Focus blog. UPPO members can view the webinar via the On-Demand Webinars page.

Should all unclaimed income tax over-withholdings be coded as TW, or are there other codes that may apply?
In short, yes. The NAUPA II reporting format does not provide for more than one deduction code. NAUPA III might, but that remains to be seen. Additionally, if those funds were withheld and reported to a taxing body, TW is the appropriate code.

When states have not adopted NAUPA codes for HSAs, can that be interpreted as they are not required to be escheated? Should it always be assumed that HSAs are to be treated like custodial/fiduciary accounts if they are not otherwise specified? How do other FIs handle the varied and sometimes absent guidance on HSAs when some states have more established guidance and laws than others?
A good rule of thumb is that if a property type is not specifically exempted in the law, then it should be considered reportable under the catchall provision. Handling HSAs under the fiduciary provisions in many of the state laws is a preferred practice because, if you are offering them and – much the same as with an IRA – your institution is playing a custodial role, and there are federal regulations that govern how you handle HSAs. For those states that do not use the HSxx codes, you are going to reach out to determine which code to use. Some of the service providers have already done that legwork, so it might be a good idea to check with them too.

We are under audit by a state, and neither the holder nor our vendor has heard anything from the state since November 2024? Our vendor reaches out monthly, but there is no reply. Any advice?
Unfortunately, you cannot control the state. They could be undergoing administrative changes/issues. We recommend:

Document all communication attempts to contact the state and any delivery and read receipts.
Continue due diligence and compliance efforts.
Work with your vendor to maintain an audit-ready posture. This includes organizing records, completing any outstanding due diligence, and reviewing your unclaimed property policies and procedures to ensure compliance with this audit state's requirements, as well as all applicable states.

Who is the owner of funds that were fraudulently deposited? Ex ID theft or forged checks. It doesn’t belong to the fraudulent account. Do you escheat in the payer’s name and paying bank if the checks are never charged back to us?
The owner of those funds would be considered “unknown.” We report these to our state of domicile as owner unknown and use an Unidentified Deposit (AC07) or Misc. Intangible (MS17) property type code.

Is there a difference between Delaware Notices of Examination to holders and the Verified Report Notices to holders? Are these separate examinations?
Yes, there is a distinction between Delaware's Notices of Examination and Verified Report Notices as they relate to unclaimed property, and they represent separate processes. However, both are mechanisms used by the Delaware Department of Finance Unclaimed Property Department to enforce compliance with the state's unclaimed property laws.

How are holders handling CT’s new email due diligence requirement?
Holders are revising their customer onboarding and account management processes to systematically collect and verify email addresses at the point of account creation and during ongoing interactions. This ensures they have valid email addresses for due diligence purposes. For example, holders are encouraged to confirm email addresses alongside physical addresses and phone numbers at every point of contact to maintain up-to-date records.

Can you recommend a software for that letter tracking?
We recommend visiting UPPO’s Service Provider and Vendor Directory for a list of member service providers.

CK005 under the NAUPA III format will be for Government Warrants. Should holders be looking at the property types to be used for both NAUPA II and NAUPA III file formats, and how to translate from the older version of the file format to the new version of the file format?
That is going to have to happen at some point. The recommendation would be to wait until NAUPA III is actually adopted. Just as with NAUPA II, it is likely that not all states will use all of the property type codes available or may repurpose some for use in their states.

If an account doesn't have a bad address but is set up for e-statements and isn't signing in to view them, do you still exempt them from escheatment if the state allows nonreturn of mail as an exemption?
We do not. Remember that the reason that rule exists is because, in those states, the presumption is that nonreturned mail is delivered mail. With e-statements, we have a unique situation in that we not only post the statement, but we can sort of see into the mailbox, so we know if the owner actually accessed what we sent them. Also, what about multiple owner accounts? Even if one owner did not access the statement, have we checked to see if the other owner did?

Where can we find a list of state requirements, such as which states allow linkage for banking property?
Many of the unclaimed property service providers offer reference materials for these types of things. UPPO’s Service Provider and Vendor Directory helps identify member service providers. Otherwise, you will need to scour the state laws and put together your own references, updating them each time a law is changed.

How do we handle pandemic relief funds that have not been returned/claimed? What are the state requirements for this type of property?
We escheat them to the state of the owner's last known address unless we know them to be part of a fraud situation. When we don't know of a specific property type they belong in, we will usually report the funds as MS17 – Misc. Intangible Property.

What are your tips for tracking state rules and regulations?
First and foremost, govWATCH. It is more than just a weekly email. It links into MultiState, which can get you to more specifics. This is one of the great benefits of UPPO membership. Next, make sure your organization has someone who monitors for changes. Most state legislatures are busy during the first four to six months of any year, but a few are whole year sessions. Many organizations have this monitoring in their legal departments.

When attempting to recover unclaimed funds from the state of Massachusetts, the Massachusetts Dept of Revenue intercepted the funds due to us for “past due taxes.” Is the state able to take our funds for other reasons?
This is going to vary from state to state, depending on whether offsetting due to outstanding state debts or court obligations (think child support) is built into their laws – not just into their unclaimed property laws, but in other laws as well.

Any thoughts on the best way to approach differences in legal interpretation versus compliance interpretation versus practical application limitations?
The best way? Collaboration. There should be a relationship that involves Legal, Compliance, Risk, and Processing. Determining what you can and cannot do is going to be an internal risk-based process, but regular collaboration keeps you on the same page. The second component is consistency. A steady, reliable, and documented approach is your best tool. Remember that policy and procedure are written for the usual approach and not for the exceptions.

State VDAs Q&A

Wed, 30 Jul 2025 19:16:07 GMT

State administrators from Illinois, Montana, Nevada and New Jersey recently participated in UPPO’s VDAs Explained: A Talk with the States to answer questions about voluntary disclosure agreement programs. Because limited time prevented presenters from responding to some of the participant questions during the webinar, they kindly agreed to respond for publication on UPPO’s Unclaimed Property Focus blog. For the convenience of readers who were unable to attend, questions that were addressed during the webinar are also included. UPPO members can exclusively access the webinar on demand.

Do any of the states use third parties for VDA support? If so, in what capacity? If not, do they ever intend to?
The four states participating in the webinar do not use third parties for VDA support and do not intend to at this time.

When is it better to submit a report with a few late items as opposed to going through the VDA process – for example, if you identify an account that has been overlooked?
Contacting the state in this scenario to request a waiver may be most appropriate. The state unclaimed property offices are here to help. If you do not feel comfortable reaching out, then factors to consider in the decision include the amount of penalties and interest that could be assessed, the waiver options and whether a one-time waiver prevents the holder from being eligible for a future VDA.

VDAs provide education and guidance to holders who have never reported, are unsure of the reporting process or have limited to no knowledge of unclaimed property. A VDA offers a fixed lookback period and review timeline and ensures compliance with regular communication from state experts.

What could you do to prepare in advance for a VDA, before you are constricted to a time frame by the state? How would you estimate the amount being reported?
In general, the states recommend reviewing the state’s unclaimed property holder manual to understand reporting requirements prior to beginning to review your records to determine what may be considered unclaimed property. As long as holders are responsive and cooperative in the process, the states can generally accommodate reasonable delays.

Estimation can vary by state and would be discussed with the holder, as it would depend on the circumstances.

Hiring an advocate firm is another option. These firms have professionals who specialize in understanding the varying requirements of state unclaimed property reporting and VDAs and can help holders identify issues that may arise in a VDA prior to entering into the program.

New Jersey
New Jersey recommends that holders review their records related to outstanding payroll checks, outstanding operating expense checks, outstanding refund checks, and any receivable credit balances for potential property subject to reporting. This would include a review of bank statements, general ledger extracts and journal entries. The purpose is to identify potential outstanding checks and receivable credits that may have been written off. These items would require further review to determine if they are, in fact, subject to reporting to the state.

If the holder’s state of incorporation is New Jersey, all relevant items, regardless of state of last known address, that are determined to be liabilities, are to be included as a basis for estimation for the period covered under the VDA where records are not available.

The holder will need to review financial statements going back years that may be retrieved from prior years’ tax returns to identify relevant numbers for estimation purposes. Examples are as follows:

Payroll expense: Total outstanding payroll checks for the period when available, and apply to the total payroll expense for the same period. Use that factor and apply it to prior years’ payroll expenses to estimate unclaimed property liability for the years to be included in the VDA.
Operating expense: Total outstanding operating expense checks for the period when available, and apply to the total operating expenses for the same period. Use that factor and apply it to prior years’ operating expenses to estimate unclaimed property liability for the years to be included in the VDA.
Receivable credit balances: Total outstanding receivable credit balances for the period when available, and apply to the total revenue for the same period. Use that factor and apply it to prior years’ revenue to estimate unclaimed property liability related to credit balances for the years to be included in the VDA.

What's the split between VDAs and audits in the state? Which program tends to be more effective?
Both programs have their place in the effectiveness of unclaimed property administration. For example, when an audit is conducted, the states try to educate and assist the holder with recommended best practices and areas where there is higher risk in internal controls. This would likely not occur during a VDA. A VDA would be effective and efficient if the holder is aware of the unclaimed property laws and regulations of the state where the additional review/analysis of an audit may not be required. If a state is contacting a holder for an audit, that means the state noticed the holder’s noncompliance in the form of misreporting property types, under-reporting or late reporting.

New Jersey
New Jersey uses several third-party firms for audits. The state also has its own field audit program with 16 auditors. It is estimated that there is an approximately 90% – 10% split between audits and VDAs. The VDA process is generally completed within six months. The goal is to encourage holders who previously never reported unclaimed property to begin to report. Audits generally will take much longer, especially for the first priority state (state of incorporation). Audits cover 15 report years, while VDAs cover 10 report years. Some holders have never previously reported, while others may have underreported.

If the person sends back a due diligence letter but fails to cash the check, does this reset the dormancy time frame?
New Jersey
If a due diligence letter is sent for a cash obligation that meets the abandonment criteria and the individual signs and mails back the due diligence letter indicating that they are owed the funds, the issuance of the check does not restart the abandonment clock. The check needs to clear, or it will be required to be reported and remitted.

Illinois, Montana and Nevada
Consider the signed due diligence letter as owner activity resulting in resetting the dormancy of that check. The date of dormancy would reset to the date of the communication rather than the date of the check issuance.

Is the Montana VDA available only to first-time filers?
The VDA is generally only for first-time filers. Montana reviews VDAs on a case-by-case basis, and there may be situations that could qualify a company that does have a filing history to enter into a VDA.

Regarding Nevada expedited VDAs, if a holder is not accepted into the program, what would be the potential next steps for the holder? Could this potentially trigger an audit?
If a holder is not accepted into the program, they will receive a denial letter that contains a link to other waiver options. This does not necessarily lead to an audit.

For New Jersey, if we do not have a new address and the person is deceased, do we still have to send a due diligence letter?
If the company has proof that the address on file is incorrect, a mailing is not required. If it has been determined that the person is deceased and there is no updated address information, then a mailing is not required.

What is the best email address for submitting VDA?

Montana: UnclaimedProperty@mt.gov
Nevada: There is no email address as it’s an electronic submission. VDA contracts can be found here. If you have questions for our office about reporting, you can reach out to NVHolder@NevadaTreasurer.gov or to UPAudit@NevadaTreasurer.gov.
Illinois: Upcompliance@illinoistreausurer.gov
New Jersey: upa4compliance@treas.nj.gov

Legislative and Regulatory Update Webinar Follow-Up Questions

Thu, 24 Jul 2025 17:33:31 GMT

UPPO’s recent Legislative and Regulatory Update Webinar webinar featured four state administrators answering common questions about VDA programs. Because limited time prevented presenters from responding to some participants' questions during the webinar, they kindly agreed to respond for publication on UPPO’s Unclaimed Property Focus blog. The webinar is available exclusively to members on demand.

Is the Maryland registered mail requirement only for retirement accounts?
The update provided was specific to the Pension and Retirement account provision added to Maryland H.B. 761 (17-306.1), which requires a holder to contact the owner via registered mail if the electronic mail bounces, the holder doesn’t have sufficient information to send an email, believes the email address to be invalid or the owner does not respond within 30 days. Holders should review the Maryland Unclaimed Property statute in its entirety for other registered mail requirements not mentioned in this bill.

Have recent state updates been made to the UPPO Jurisdiction Resource Guide?
Jurisdiction Resource Guide updates occur annually. The next update is scheduled to occur by the end of summer.

You addressed the need for two years to pass before a holder can make a claim in Colorado. Do any of these states’ laws require a moratorium period before a claimant rep can assist someone in claiming their funds from the state?
This bill limits a holder to filing claims for reimbursement to doing so within two years of remitting and reporting the money paid. It does not require the holder to wait for two years to pass before making a claim.

Per the reduction in threshold for Washington (from $75 to $50) effective on July 27, 2025, does this mean we need to update our mailout for this year? We have already completed this process. Do we need to go back and revisit the letters for Washington?
Typically, when a bill is effective after the state cutoff date, the changes made by the bill would not go into effect until the following year’s report date. However, some states have indicated that they expect compliance in the current year. We are unaware of any official position made by Washington on this issue.

Lawsuit Challenges Ohio’s Plans for Unclaimed Property

Sun, 20 Jul 2025 20:44:56 GMT

On June 30, 2025, Ohio Gov. Mike DeWine signed the state’s budget bill, H.B. 96, into law, including a provision that allows the state to use unclaimed property to fund a new stadium for the Cleveland Browns and future sports and cultural facilities.

Under the new plan, property owners have a 10-year grace period to claim funds held by the state, after which the Ohio Stadium and Cultural Facilities Fund will take possession of any property held for more than 10 years.

On July 7, 2025, three Ohio citizens filed a class action lawsuit against state officials, challenging the constitutionality of the state’s plan.

“Under the statute in force prior to June 30, 2025, Ohioans had no restrictions on their ability to seek recovery of their property held in the UFA,” the lawsuit claims. “However, the State now intends to confiscate the private property held in the UFA for the purpose of funding a private development, depriving the rightful owners of their property. The State intends to do so even though it has been long settled that funds held by the State of Ohio in its ‘Unclaimed Funds’ account are private property. The UFA is not property of the State of Ohio to use as it deems fit.”

The lawsuit argues that the plan violates the U.S. Constitution’s 5th and 14th Amendments, as well as Article I, Section 19 of the Ohio Constitution, and the statutory fiduciary duty imposed by Ohio Revised Code Chapter 169 to preserve the funds for the actual owners of this private property.

View the lawsuit.

Due Diligence Basics

Fri, 11 Jul 2025 19:41:32 GMT

With unclaimed property audits being an ongoing concern for holders, it is more important than ever to get on track with performing due diligence if your company is not already in compliance.

Unclaimed property due diligence is a specific type of communication deemed legally necessary by most states and territories to make individuals aware of the impending transfer of their property to another holder.

The objective of due diligence is to return unclaimed property that has remained dormant on a holder’s books to the rightful owner. Due diligence mailings to last-known addresses that the holder has on record are considered the most effective and efficient method of achieving this goal.

Holders should review all addresses for completeness prior to mailing. If an address is known to be inaccurate or if the address is unknown, the holder may want to attempt to locate a current address for the owner.

Unlike other types of mailed communications to property owners, such as courtesy mailings, due diligence is a formal notice at the end of a property’s dormancy period. Holders are responsible for sending letters to the owner’s last-known address, stating that the property will be turned over to the state if the owner fails to respond within a specified timeframe.

Most states require that a written notice be sent via first-class mail. However, New York and Ohio require letters to be sent by certified mail with a return receipt for accounts equal to or greater than $1,000. New Jersey’s certified mail with return receipt applies to accounts of $50 and higher. Notices for lower amounts can be sent by first-class mail.

While the Uniform Unclaimed Property Act states that properties with a value of $50 or more require due diligence, some states have determined alternative values that require due diligence. For example, the more lenient Texas requires mailings only for values of $250 or more, while Connecticut and New York require holders to send notification to all owners with a valid address, regardless of the value of the property. A small number of states and territories do not require due diligence at all. Because property value thresholds vary, holders should refer to individual state statutes.

Even if a particular property is not of value to require due diligence, there are still aggregate minimums for reporting purposes. It is important to note that while some states use the same thresholds for aggregate and due diligence limits, they can be different. Don’t confuse the two. For example, California has an aggregate threshold of $25, but a due diligence threshold of $50. In Michigan, if a holder is reporting 25,000 or more properties of at least $50 in value, due diligence notices must be sent only for properties valued at $100 or more. Oklahoma, however, lowers the threshold to below $50 (including items of all values) for items from a set of recurring payments, such as royalties, annuities, dividends, distributions, etc.

Most states and territories require that the due diligence letter include the language, “The holder is in possession of property subject to this Act.” This wording is significant because the due diligence mailings cannot include qualifying language or any words and phrases that may lead owners to believe they may not be the owner of, or entitled to, the property.

California, in particular, has stringent guidelines covering what is required in due diligence mailings to owners living in the state. The letter must contain a heading at the top that reads: “THE STATE OF CALIFORNIA REQUIRES US TO NOTIFY YOU THAT YOUR UNCLAIMED PROPERTY MAY BE TRANSFERRED TO THE STATE IF YOU DO NOT CONTACT US,” or uses substantially similar language.

The notice must specify the time that the property will escheat, and the effects of escheat, including the necessity for filing a claim to California for the return of the property.

The notice must also, in boldface type or in a font a minimum of two points larger than the rest of the notice, exclusive of the heading:

Specify that since the date of last activity, or for the last two years, there has been no owner activity on the deposit, account, shares, or other interest.
Identify the deposit, account, shares, or other interest by number or identifier, which need not exceed four digits.
Indicate that the deposit, account, shares, or other interest is in danger of escheating to the state.
Specify that the unclaimed property law requires business associations to transfer funds of a deposit, account, shares, or other interest if it has been inactive for three years.

California requires that the owner has the option to maintain the property on their account to be collected or used later, or has the option to be issued payment promptly. Other options can be allowed depending on the nature of the property. For example, if the property is a credit on a customer account, the customer could also be given the option to apply the credit to a past due or upcoming bill.

This letter must also allow the owner to correct their address if necessary. The holder can also give the owner the option to return their response via fax or email.

California also sends its own due diligence letters based on the holder’s preliminary report. A sample of California’s due diligence letter can be found on the state’s website.

Ohio also has more specifications than most states when preparing due diligence mailings for its residents. Similar to California, the letter must list specifics of the property, notably its nature, ID number or description of the property, and amount. The notice must also inform the owner that the property will be transferred to the state within 30 days, unless the holder receives earlier contact.

Unlike other states, Ohio requires the holder to provide owners with a self-addressed, stamped envelope for return communication.

When mailing letters to owners in multiple states, the same body text may be used as long as content requirements of all states are met. Although Ohio and California are specific in what they require in a due diligence letter, most of these required elements can be considered best practices for all due diligence mailings.

A few jurisdictions currently have advertising or publication requirements, including New York and Puerto Rico. Refer to individual state statutes for jurisdiction’s requirements.

As with other aspects of due diligence, little uniformity exists regarding the timing of mailings. Most states and territories follow the Revised Uniform Unclaimed Property Act timing, which calls for sending the letters between 120 and 60 days before reporting the property to the state. Other states and territories have adopted their own timing standard. For example, California’s unique due diligence requirements require its holder due diligence mailing to be sent between 365 and 180 days before reporting. Holders need to confirm each state’s requirements when preparing their due diligence mailings.

When building your timeline for mailing due diligence letters, keep in mind that best practices recommend providing 30 to 60 days for the property owner’s response.

Providing a response deadline in due diligence letters lets owners know there is limited time to claim their property directly from the holder, so doing so is considered a best practice. Clearly state that the property will no longer be in possession of the holder after the response deadline date.

Finally, it is best to examine state statutes on a periodic basis before performing due diligence and reporting. This information is readily available through state websites. Laws are amended occasionally, and such changes can occur at any time. It is vital to be aware of any and all legislative changes to ensure that you and your company is fully compliant.

Unclaimed Property News Roundup

Tue, 24 Jun 2025 13:20:51 GMT

Unclaimed property often makes news headlines. UPPO occasionally provides a snapshot of some of the more interesting and entertaining stories receiving coverage from local and national media outlets recently.

WSYX reported on June 19, 2025, that Ohio lawmakers are considering using $1.7 billion in funds held by the state’s unclaimed property office to help fund a new football stadium for the Cleveland Browns. The plan has generated significant controversy, according to subsequent reports from News 5 in Cleveland on June 18 and June 23. Critics quoted in the news stories include UPPO member Jennifer Borden and NAUPA Legal Committee Chair G. Allen Mayer.

On May 1, 2025, News Talk 103.7 published a story about two Connecticut siblings who allegedly submitted more than $1.2 million in fraudulent unclaimed property claims. According to criminal charges filed by a U.S. attorney general in Pennsylvania, the pair received and cashed payments from various state treasuries for corporate entities with which they had no legitimate connection.

On April 15, 2025, WPVI News reported on a man’s failed attempt to claim nearly $60,000 from New Jersey’s Unclaimed Property Office by cashing in 389 gambling chips from a long-defunct Atlantic City casino. Unfortunately for the attempted claimant, an investigation revealed that the chips had not been acquired through casino play, but rather stolen by a former employee, rendering them relatively worthless, according to state regulations.

DEIB Spotlight: Fatherhood

Tue, 17 Jun 2025 18:11:26 GMT

DEIB Spotlight is a UPPO DEIB Task Force initiative that celebrates the organization’s diversity by highlighting subjects and members that help make UPPO a welcoming association for all unclaimed property professionals.

Each June, we celebrate dads on Father's Day. Whether being a father in a traditional or blended family, raising kids as a single dad or in a same-gender marriage or partnership, parenting in an interracial household, or serving as a father figure, the dynamics of fatherhood vary from family to family. In some cases, the journey to fatherhood can also take several different paths.

Johan Boakes

At the age of 52, UPPO member Johan Boakes wasn’t expecting to become a father. He had been married and divorced, and although he wanted kids, it simply hadn’t worked out. Then fate intervened when he met the woman who would become his second wife. She had two sons from a previous marriage.

As the relationship progressed and became serious, Johan was slowly integrated into the family. Now, he’s “Pops” to nine- and 11-year-old sons.

“They have their dad, who is a very good friend of mine, and they have their Pops,” he said. “I feel very fortunate that the boys were young enough that I’m a full-fledged ‘Pops,’ or, as they tell their friends, their other/second dad.”

Being a stepfather can include extra challenges if parenting styles don’t mesh with either the mother’s or father’s. “Even though I didn’t have children when I met Chelsie, I am proud to have five godchildren (ages 16-38), and I have seen many friends’ children grow up,” he said.

Johan has the enviable position of having a cohesive, kids-first approach with the children’s other parents. As their relationship developed, he and his wife frequently discussed their backgrounds, values, and approach to parenting. They found they were in sync, and together they made a great team. Fortunately, their father has a similar approach.

“Neither their dad nor I is trying to supplant the other one,” Johan said. “He’s a good guy, and I’m grateful for the opportunity to be a co-parent. It’s incredibly rewarding on a 24/7 basis, whether it be cooking the children’s meals, playing soccer, dinosaur chase, celebrating successes and helping my sons navigate disappointments or just teaching them something important that will help them be the best people we know they can be.”

Taking on a fatherhood role after 50 has been extremely rewarding, giving Johan’s life a different meaning. “I’ve always thought good friends and good family are the true riches of life,” he said, “True wealth and meaning are your legacy, and helping to raise two great boys gives my life more purpose. Every day is an adventure.”

Johan embraces the full-time nature of parenting and recognizes the need to make time to recharge.

“The priority is always the children,” he said. “But Chelsie and I don’t forget to carve out a little bit of time to recharge our batteries as a couple and as individuals. As parents, you need to take care of yourselves so you can take the best possible care of your children. I am the very proud Pops, my sons who are kind, funny, empathetic, intelligent, just wonderful boys.”

Christopher Jensen

UPPO member Christopher Jensen and his wife, Lexie, have three sons, Maddox (10), Oliver (4) and Theodore (9 months), each with a unique origin story. In 2011, a few years into their marriage, the Jensens decided to begin expanding their family. After a couple of years without results, they sought medical assistance, which ultimately brought them to an in vitro fertilization (IVF) clinic in Dallas.

The IVF process is complex and costly, including in-depth testing of both prospective parents, daily shots for the mother, leading to retrieval and insemination of the eggs. After the fertilization process, those embryos with the greatest chance of survival are identified, frozen and eventually transferred to the mother at a later date. Each transfer leads to follow-up monitoring and testing, which can last for months before knowing if a pregnancy is viable. Multiple transfers can be necessary, and if none of the embryos implant and continue developing, the harvesting and retrieval process needs to be repeated.

After two failed transfers, the Jensens were fortunate to have success with their third transfer (fifth embryo), and Maddox was born in 2015.

“I always look back at that time as such an emotional roller coaster,” Chris said. “But we got what we desperately wanted, which was to be parents. Maddox came along, and life was great. After about a year or so, we decided to get started on number two.”

In 2017, using the sixth and final embryo from their first round of IVF, the Jensens began working on expanding their family again. When it was unsuccessful, they started the entire process over. Unfortunately, multiple transfers resulted in false hopes. The process would seem fine for the first few months before resulting in a miscarriage. Now diagnosed with secondary infertility, and with criteria met after having three consecutive miscarriages, the Jensens eventually were referred to a world-renowned specialist in recurrent pregnancy loss, who was unable to find anything wrong and advised them to keep trying.

In January 2019, Chris and Lexie received a phone call out of the blue with an unexpected offer from Chris’s younger sister. She said that after having two daughters, she and her husband were not planning on having more children, but she would be willing to help her brother’s family by serving as a gestational carrier if they were in need.

“We were blown away,” he said. “We thanked her for the offer and told her we would keep it in mind. Unbeknownst to my sister, we had our eighth transfer scheduled for the very next day, so we tucked the offer in our back pocket and proceeded with our scheduled plan.”

Sadly, like the previous attempts, the pregnancy failed at about 11 weeks. Running out of options, the doctor suggested something that had not been discussed over their seven-year journey – trying again with another carrier. The Jensens told the doctor about Chris’s sister’s offer from the months prior, and they quickly began planning their new path to a second child.

“It sounds easy on the surface, but it’s a lot more complicated than one would think,” Chris said. “Logistically, medically, legally. There was also a counseling process for all of us because going through this is so emotionally and mentally challenging, so everyone needed to be prepared.”

In June 2019, they transferred two remaining embryos to the carrier. Unfortunately, they didn’t take. They received the news on the way to their airport, about to embark on an 11-day European vacation. It was devastating, as they all thought this was the key to success. While in Europe, Chris and Lexie arrived at the conclusion that it was time to close this chapter of their journey. The mental, emotional, physical and financial exhaustion had taken its toll. Upon their return to the States, they met with their doctor to close the loop. Then, they received yet another unexpected offer. This one came from their doctor.

“He came into the meeting and said, ‘Before you say anything, just hear me out. You’re probably done with this, but we’ve been going through this together for eight years. The nurses and I have gathered up donated medicines over the last week, and I’ll do everything for free. I don’t want to see you give up yet, and I’d like to try one more time. Just don’t quit.’ We were moved to tears by the gesture,” Jensen said.

With Chris’s sister on board for round two, Lexie and Chris began the medication, retrieval and fertilization process again, this time only producing three embryos. The first two embryos failed from a transfer right before the pandemic. Realizing their journey was coming to an inevitable end, they began to consider alternative methods to expand their family, including adopted embryos or outright adoption. In September of that year, they started the process for adopting embryos, but simultaneously went ahead with their final embryo transfer. Given their history, expectations were low, but much to their surprise, their 20th and final embryo implanted. However, the path to child #2 was not without one more twist. About 36 weeks into the pregnancy, Chris’s sister called Chris early in the morning with the news that pre-term labor had begun. Chris and Lexie immediately booked the only flight up to Bismarck, North Dakota, that evening, where their second baby boy, Oliver, was born just one hour after their flight landed.

“That was it,” Jensen said. “We thought our story had been written. Then, days before last year’s Super Bowl, my wife said, ‘Sit down. We need to have a talk.’ She disappeared into the bedroom for a minute while I tried to figure out what was wrong and returned with a shoe box containing several positive pregnancy tests.”

Indeed, Lexie was pregnant and, much to their surprise, the unexpected, natural pregnancy proceeded without complications week after week and month after month. At 37 weeks, Lexie’s water broke during her baby shower. They got to the hospital for an emergency C-section and soon welcomed their third son, Theodore, to their family.

After three sons, three different paths to fatherhood, two selfless acts of generosity and one completely unexpected postscript, what advice would Chris offer other prospective parents having trouble conceiving?

“Keep going until you run out of time or money. Just keep going. Some miracles just take a little bit of time.”