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COVID-19 State Reporting Guidance

Last updated on May 22, 2020

 

Thanks to the COVID-19 pandemic, “business as usual” has become unusual for most people. Because spring unclaimed property reporting season is upon us, some holders have contacted UPPO, wondering whether states are granting extensions to companies that are unable to meet filing deadlines as a result of COVID-19 disruption to regular business.

 

UPPO reached out to states with reporting deadlines between March 1 and July 1 regarding extensions in light of the COVID-19 outbreak business disruption and subsequently asked NAUPA to pose a series of additional questions to all state administrators. In addition, UPPO updates this page as states provide additional updates. Following are the responses, organized by state. NAUPA is also collecting and posting COVID related information from states on its website

 

ALASKA
Due Diligence Extension: 
Alaska will work with holders on all due diligence matters, including extensions.

Safe Deposit Box Guidance: Alaska will gladly extend the filing and remittance dates for safe deposit property.

Foreign Property Guidance: An email notification will suffice. If not available, file an extension and hold off until due diligence can be completed. 

 

CALIFORNIA
Reporting Extension: 
The June 1-15 period for holders to submit their reports and remittances for properties reported on 2019 Notice Reports is extended from June 1, 2020, to August 15, 2020. See holder notice.

 

CONNECTICUT
Reporting Extension: 
At this time Connecticut’s statutory reporting deadline has not changed – March 30, 2020. However, the state is asking everyone to send in the report as quickly as possible. Connecticut has decided to temporarily accept a copy of the executed and notarized coversheet. Holders should visit the state’s website for important information regarding reporting unclaimed property. Send holder questions to CTHolderReport@ct.gov.

 

DELAWARE 
Reporting Extension: Delaware’s spring reporting deadline for most holders (excluding insurance companies and banking organizations) was March 1, 2020. The state’s Office of Unclaimed Property understands that holder business operations are likely to be impacted by the coronavirus. Holders are encouraged to file their annual reports and remit payment and securities as soon as feasible. Those holders that require an extension for filing their annual report will be granted a 30-day extension upon written request to Escheat.holderquestions@delaware.gov. Additional extension requests should also be submitted in writing to the same email address.  

 

DISTRICT OF COLUMBIA

Reporting Extension: D.C. has been granting extensions to holders during the pandemic for current reporting cycle. We have received and granted more than 60 requests for extensions from holders for the current period.

Due Diligence Extension: We will consider and plan to approve extensions for holders who couldn’t meet the due diligence requirements during the current stay-at-home guidelines imposed by most states. We do understand that this will prolong the reporting process and that holders will subsequently need an extension for the fall reporting cycle.

Safe Deposit Box Guidance: D.C. will allow holders of safe deposit boxes to file extensions for the reporting periods that were impacted during the crisis.

Foreign Property Guidance: D.C. will most likely approve extensions to report property of owners with foreign address. Holders should seek permission to exclude properties that have foreign address on record. When postal restrictions are lifted and enough time has passed for due diligence to be performed those properties still found to be dormant can be reported on a subsequent report.

 

ILLINOIS
Reporting Extension: A 30-day extension will be automatically granted to all annual reports due by April 30, 2020 for requests submitted via email to up_report@illinoistreasurer.gov. Administrative rules require extension requests be received at least 15 business days before the due date. Thus, requests should be sent before the close of business on April 9, 2020. Additionally, interest and late-filing penalties will be waived for up to 60 days after the end of the emergency declaration in Illinois.

 

INDIANA
Reporting Extension: 
Indiana does not have any plans to grant automatic extensions. Holders may still file an extension with our office per the instructions on our website.

Due Diligence Extension: Indiana is not considering due diligence extensions, but we will consider this as a reason for a holder to file a reporting extension request for the November reporting season.

Safe Deposit Box Guidance: Indiana will consider this as a reason for a holder to file a reporting extension request for the November reporting season.

Foreign Property Guidance: Indiana will consider this as a reason for a holder to file a reporting extension request for the November reporting season.

 

KANSAS
Reporting Extension: 
Kansas grants an automatic extension of May 1 Life Insurance reporting deadline to July 1.

Due Diligence Extension: Since Kansas is a Nov. 1 report state for all property types other than Life Insurance, we believe it is too soon to extend our due diligence requirement deadline of July 1. Kansas will revisit potential due diligence extension on June 1.

Safe Deposit Box Guidance: Kansas grants an automatic extension of Nov. 1 reporting for Safe Deposit Box and Safe Keeping type properties only to Jan. 1, 2021.

Foreign Property Guidance: Since Kansas is a Nov. 1 report state for all property types other than Life Insurance, we believe it is too soon to extend our due diligence requirement deadline of July 1. Kansas will revisit potential due diligence extension on June 1.

 

MICHIGAN
Reporting Extension: 
Michigan has not made any changes to its July 1 filing deadline. Statute provides holders with an option to request a 60-day extension. The state will take those requests into consideration as they are received.

Due Diligence Extension: Michigan is considering individual extensions as they are requested. If an extension is granted, it will be for 60 days, making the due date Sept. 1. Due diligence should be performed by July 1 for holders with extensions.

Foreign Property Guidance: The due diligence letter should be mailed as soon as U.S. Postal Service restrictions are lifted. Proceed with the regular reporting process. It is advisable to include in the letter that, if a response is not received, the property will be reported to Michigan on *date* and provide Michigan Unclaimed Property’s website address. This will assist them in locating their property and establishing a claim, if the letter is late in getting to them.

 

MISSOURI
Reporting Extension: 
Missouri is automatically granting an extension for the May reporting period when receiving an email requesting such. The state’s notice says, “The Missouri State Treasurer’s Office understands that businesses are likely to be impacted by COVID-19 and the subsequent business interruptions, etc. Because of this, holders that require an extension for reporting unclaimed property will be granted a 30-day extension when requested in writing. Holder needing more than 30 days, but not exceeding 90 days, should put the additional time requested in writing. Please reach out to UCP@treasurer.mo.gov with written requests or with any questions.”

Report Notarization Waiver: The Missouri House and Senate passed H.B. 1655 and sent it to the governor on May 15, 2020. The bill includes provisions allowing for an electronic signature to satisfy notarization requirements contained in state statutes, regulations or ordinance. 

 

NEW HAMPSHIRE

Reporting extension: No blanket extensions but will grant any extensions received. New Hampshire will not assess penalties or interest so long as good faith effort is made.

Due Diligence Extension: If holders can't do due diligence, New Hampshire will allow a reasonable time to finish due diligence.

Report Notarization Waiver: If uploading through state's portal, New Hampshire is not requiring notary. New Hampshire's governor issued an order that notaries do not have to be in person.

Foreign Property Guidance: New Hampshire will provide reasonable time after things are "back to normal." 

 

OKLAHOMA
Reporting Extension: 
Holder may request an extension.

Due Diligence Extension: Holder may request an extension.

Safe Deposit Box Guidance: Holder may request an extension.

Report Notarization Waiver: Please refer to the Oklahoma Treasurer’s website for temporary form not requiring notary.

Foreign Property Guidance:Holder may request an extension.

 

PENNSYLVANIA
Reporting Extension: 
The Pennsylvania Treasury is granting a waiver for holders that will be unable to report and remit unclaimed property prior to the annual April 15 reporting deadline. For any holders in need of additional time, please notify Treasury via email at report@patreasury.gov.

 

SOUTH DAKOTA
Reporting Extension: 
South Dakota has extended the spring deadline until June 1. There is no decision at this time regarding the November deadline.

Due Diligence Extension: South Dakota will accept Life Insurance reports prior to June 22 without penalty if the delay is for due diligence.

Safe Deposit Box Guidance: No extension at this time since they are due Nov. 1.

Foreign Property Guidance: South Dakota will allow email contact during this time.

 

TEXAS
Reporting Extension: 
We have no plans at this time to extend the July 1 reporting deadline. We do not have the authority to automatically extend the reporting deadline. However, waivers of penalty and/or interest assessments for property delivered late will be evaluated on a case by case basis.

Due Diligence Extension: Texas has issued due diligence guidelines for 2020 reporting

Safe Deposit Box Guidance: Texas understands the concerns related to the remittance of tangible property. We would expect that holders still report tangible property by the filing deadline, July 1. However, we will not schedule the delivery of any tangible property until the current situation improves.

Foreign Property Guidance: While we understand the suspension of mail service to certain countries may inadvertently result in some properties being reported as unclaimed property because an owner was not able to receive notice, we do not have the authority to change or suspend the mailing requirement.

 

VERMONT
Reporting Extension: 
Vermont is automatically granting an extension for the reporting period when receiving an email requesting such. The state’s notice says, “The Vermont State Treasurer’s Office understands that businesses are likely to be impacted by COVID-19 and the subsequent business interruptions, etc. Because of this, holders that require an extension for reporting unclaimed property will be granted a 30-day extension when requested in writing. Holder needing more than 30 days, but not exceeding 60 days, should put the additional time requested in writing. Please reach out to TRE.UPCompliance@vermont.gov with written requests or with any questions.”

 

WEST VIRGINIA
Reporting Extension:
 For life insurance companies, West Virginia has decided not to extend the deadline. Upon request, individual extensions are being granted.

Due Diligence Extension: Our filing deadline for non-life insurance holders is Nov. 1. Due diligence will not start until July 1 for West Virginia properties. As we move closer to that date, we will reevaluate if an extension is still needed.

 

Thank you to NAUPA for its assistance gathering this information and to state administrators who have responded. UPPO invites states to email updates to toni@uppo.org.

 

Holders needing to contact state administrators are encouraged to use UPPO's Spring Reporting Guide, updated in February 2020, and Fall Reporting Guide, updated in August 2019, for phone, email and other useful information. 

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