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UNCLAIMED PROPERTY FOCUS is a blog written by and for UPPO members, featuring diverse perspectives and insights from unclaimed property practitioners across the U.S. and Canada. We welcome your submissions to Unclaimed Property Focus. Please contact Tim Dressen via tim@uppo.org with any questions about submitting a blog post for consideration and refer to our editorial guidelines when writing your blog post. Disclaimer: Information and/or comments to this blog is not intended as a substitute for legal advice on compliance or reporting requirements.

 

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Litigation update: Plains All American appeal keeps estimation case alive

Posted By Administration, Thursday, January 12, 2017

One of the more interesting recent unclaimed property cases in recent years is Plains All American Pipeline L.P. v. Thomas Cook et al. In August 2016, the case was dismissed, but Plains has appealed the decision, sending the case to the Third Circuit Court of Appeals.

 

Background

A limited partnership incorporated in Delaware, Plains All American Pipeline, received notification in 2014 that Kelmar would be conducting an audit of the company on behalf of Delaware. Plains objected to the initial information request, claiming, in part, that the company was being audited not because of any suspicion of wrongdoing, but rather because of its profitability. When Delaware dismissed the company’s objections, Plains filed suit.

 

Among the complaint’s allegations, Plains argues that Kelmar’s request for information about subsidiaries organized outside of Delaware constitutes illegal search and seizure under the Fourth Amendment. The company argued that the state and its agent have no right to that information and, if they did, they would need to have reasonable grounds to search for it. The complaint also directly challenged Delaware’s right to use estimation.

 

Decision

On Aug. 16, 2016, the U.S. District Court for the District of Delaware granted the defendants’ motion to dismiss. In part, the court said the plaintiffs brought their suit based on potential threats and not actual threats. For example, Plains challenged the state’s right to use estimation before it had done so, as the lawsuit was brought immediately following Kelmar’s initial information request. Regarding the Fourth Amendment claim, the court said the state’s decision to examine businesses based on their profitability was legitimate, as those companies are logically more likely than others to hold large amounts of unclaimed property.

 

Plains was worried about going through this long audit and then getting an estimated liability,” says Diane Green-Kelly, partner with Reed Smith LLP. “They didn’t think estimation was appropriate. The way the court read the complaint was that Plains was unhappy about how the audit might unfold and what the assessment might be. The court said you can’t complain about something that might happen. You have to wait until you’ve suffered an injury. The court didn’t consider the case ‘ripe.’”

 

Status

As with any case a court dismisses with prejudice, parties involved in the case may appeal the decision. Plains All American did just that on Sept. 16, 2016, sending the case to the Third Circuit Court of Appeals.

 

Outlook

The appealed Plains case is developing at a time when Delaware’s unclaimed property practices face several significant challenges. These challenges may affect how the appeals court views the case.

 

“It’s hard to know what the Third Circuit will do, especially in light of other things,” Green-Kelly says. “You can’t look at the Plains case in a vacuum. The court will see that 21 states are suing Delaware for overreaching its unclaimed property authority. Temple-Inland won because of overreaching and ignoring federal law. Marathon and Office Depot sued Delaware. Everyone is suing Delaware. The Third Circuit will see this case in the context of a lot of things happening out there challenging Delaware’s conduct. So, the court could decide this case actually was ripe in light of the context in which it was filed.”

 

Another case, Delaware Department of Finance v. Blackhawk Engagement Solutions, could also influence the outcome of Plains. In 2015, Delaware’s escheator issued a subpoena to Blackhawk requesting documents related to an audit that had been in progress for several years. Blackhawk refused. Delaware filed an action in court to enforce the subpoena, and Blackhawk resisted, claiming the escheator was not authorized to take these actions, among other things. The state filed a motion for judgment on the pleading, at which point Plains All American and Marathon filed a joint amicus brief.

 

The brief cites several areas of the Delaware Code where state agencies are authorized to conduct examinations to determine with a set of laws and expressly authorized to issue a summons for testimony and a subpoena for documents. The unclaimed property statute authorizes the escheator to issue a summons for testimony, but not a subpoena for documents. The amicus brief points out that the code actually included such authorization until it was repealed and revised in 1990.

 

“If the Blackhawk court says the escheator has the authority to issue a subpoena and enforce it, Plains sort of goes away,” says Green-Kelly. “If the escheator actually has subpoena power and can enforce it in court, the resisting company can claim it doesn’t have authority to so and let the court decide. It happens during the audit, so the court can stop it while it’s happening. Because the statute lacks the authority to issue a subpoena, right now there’s no way to stop it other than to file the type of lawsuit Plains filed.”

 

Impact on Holders

In light of the important issues at play in Plains and other current cases, Green-Kelly offers some advice for holders undergoing an audit or considering entering into a voluntary disclosure agreement (VDA).

 

“If you’re a company already under audit and close to the end, you shouldn’t just accept a result that is not supported by documents or anything that is close to an estimate like Temple-Inland,” she says. “If you’re not under audit and are thinking about a VDA, don’t do anything. See what happens with these cases. Under the new audit program, it might be better to be audited than to go through a VDA. Wait and see what the audit program is going to be. I can’t imagine telling any company to go into the VDA program right now unless they get the letter and have to make a decision.”

 

 

Tags:  Blackhawk  Delaware  estimation  litigation  Plains All American  unclaimed property 

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Unclaimed property is ripe for fraud threats

Posted By Administration, Thursday, January 5, 2017

Whenever large amounts of money change hands, the likelihood of fraud exists. Thus, unclaimed property presents a variety of opportunities for potential fraud. Property owners, state unclaimed property departments and property holders can all be targets of dishonest attempts to profit from unclaimed property.

 

Scams directed at individual property owners have sprung up often enough to warrant consumer warnings from several states in recent years. This form of fraud usually entails someone offering to help locate property for a fee or promising a substantial (and completely fictional) windfall. Eager consumers either pay for bogus services or provide personal information that gives scammers access to bank accounts.

 

Claims fraud is another common problem. Inspired by published lists of unclaimed property owner names, people misrepresent themselves to the state in an attempt to claim property that doesn’t actually belong to them.

 

Property holders must also be on guard against potential fraud, which often comes from internal sources—employees who identify opportunities to use unclaimed property for their own gain.

 

“One reason we see fraud related to unclaimed property at the holder level is because the money has been forgotten by the owner,” says Laurie Andrews, unclaimed property reporting technical director for Keane. “It may be sitting in a GL account that nobody touches or on an uncashed check list where the check has been floating out there for an extended period of time. The apparent owner may not know about the money or doesn’t seem to care about the funds.”

 

There are multiple methods dishonest employees use to access property not belonging to them. If a single person controls the assets, and prepares and submits unclaimed property reports, they may simply replace a legitimate property owner’s personal information on the report with their own details. They then go to the state to claim the funds.

 

In some instances, they may act before the property is escheated. Just before the end of the dormancy period, rather than doing due diligence and reporting an uncashed check to the state, for example, they may void and reissue it. To reduce the chances of detection, they cut the check to their credit card or utility company—perhaps the same one used by their company—instead of making it out to themselves.

 

“According to criminologist Donald Cressey’s hypothesis, with every fraud there are three components: opportunity, rationalization and pressure,” Andrews says. “The only one of those within the holder’s control is opportunity. Rationalization and pressure are self-imposed by a person committing the act. So, holders should take steps to reduce opportunity.”

 

Internal controls to safeguard held assets include:

  • Establishing a fraud policy.
  • Segregating duties.
  • Putting checks and balances in place for movement of funds between general ledger accounts.
  • Setting up software alerts to notify managers of unusual data changes for high-balance accounts.
  • Maintaining an ethical culture from the CEO down.
  • Conducting annual or periodic unannounced internal audits.
  • Holding annual fraud training throughout the organization and ensuring internal auditors have a thorough understanding of unclaimed property.
  • Keeping fraud procedures and unclaimed property procedures current with practices and requirements.
  • Maintaining an anonymous employee fraud tip line, and responding to allegations quickly and thoroughly.

 

“Internal controls will vary across an organization depending on property type,” says Ryan Hagerty, manager for KPMG. “It starts by having an in-depth system of checks and balances.”

 

Fraud threats against holders may also come from external sources. As with internal controls, policies, procedures and processes for handling and responding to claims should be thorough.

 

“While training of claims processors is important, multiple levels of management oversight should exist to ensure true segregation of duties,” Hagerty says. “The higher the value of the claim, the more layers of approval that should be required to reduce the financial impact of fraud at each occurrence.”

 

When dealing with property that has multiple owners—funds held in trust, multiple business owners and married couples, for example—extreme care should be taken when a claim attempt is made but all of the owners are not included. Business disputes, divorces and battles between heirs can lead to one party attempting to parties attempting to get more than their fair share.  

 

“Issues can arise when payments are owed to small businesses with multiple owners, individuals whose names have changed due to marriage, joint property owners or estate heirs,” Hagerty says. “When claimants request a refund check be issued in the name of their business or to the exact name and address the holder has on record, there is less of a concern of external fraud. However, caution should be taken if an individual attempts to claim property that is jointly owned or held in the name of a business entity. It’s important to require documentation to support the validity of these claims.”

 

Scammers seeking to claim another entity’s property may use fraudulent power of attorney documents they created and had unethically notarized. Unlike estate administrators and executors that can be easily verified, powers of attorney are not commonly registered by a government entity. This puts holders in a difficult position when faced with a claim from someone presenting power of attorney documents.

 

“Sometimes holders have to depend on the ‘sniff test,’” Andrews says. “If something doesn’t feel right, it probably isn’t, so you need to look into it further.”

 

To learn more about unclaimed property fraud, join Andrews and Hagerty, as they lead the Don’t Make a Fraudian Slip session at the 2017 UPPO Annual Conference. They will discuss how holders can tighten internal controls, safeguard assets, develop procedures for validating due diligence claims, and protect themselves against other potential scams.

 

 

Tags:  employee theft  fraud  powers of attorney  unclaimed property 

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2016 Trends are sure to Shape 2017

Posted By Administration, Thursday, December 22, 2016

With 2016 coming to an end, the approaching new year offers a good opportunity to look at some of the major trends shaping the unclaimed property landscape. Over the past year, we’ve seen some significant litigation, a slowdown in new legislation and the Uniform Law Commission’s (ULC) release of the 2016 Uniform Unclaimed Property Act (UUPA). All of these noteworthy trends set the stage for what is sure to be an interesting and action-packed 2017 for unclaimed property professionals.

 

Legislation

Unclaimed property professionals have become accustom to a high volume of legislation affecting state unclaimed property statutes. While 2016 wasn’t completely absent of noteworthy bills working their way through the nation’s statehouses, there was a significant slowdown in legislative activity compared to the previous few years.

 

“Looking back at the year, I was struck by the low level of legislative activity,” says Michelle Andre, managing member of Tre Towers Advisory Group LLC. “This may have resulted from 2016 being an election year combined with states knowing the Uniform Law Commission was finalizing the 2016 Uniform Unclaimed Property Act.”

 

Some of the bills that did arise this year added to trends that have been building over the past several years. For example, states continue to modify their gift card rules. Some states that have exemptions from reporting unredeemed balance on gift cards are requiring issuers to provide cash refunds to card owners if the value of the card meets certain dollar amount thresholds. New York recently revised its gift card rules, effective on Dec. 25, delaying the trigger for when issuers can assess a service fee from after the 12th month of dormancy to after the 24th month. Another state, Wyoming removed a sunset provision allowing its gift card exemption to become permanent.

 

States are also continuing to enact provisions requiring life insurance companies to perform routine Death Master File searches. Five states passed such legislation in 2016. Although modeled loosely after the National Conference of Insurance Legislators’ Unclaimed Life Insurance Benefits Act, each of the laws are different. Florida’s law, for example, has a longer reach-back period than most states.

 

Technology has also played a role in some statute revisions as states account for increasing surge in electronic transactions and communication. California, for example revised its unclaimed property law to include electronic transactions as official contacts that prevent accounts from becoming dormant.

 

State laws are finally recognizing that people are communicating electronically rather than by snail mail or phone calls,” Andre says. “Increasingly, people stay in touch with investments via the internet rather than by making a call or waiting for a statement in the mail.”

 

Pennsylvania also included electronic communications provisions within unclaimed property statute revisions that were tucked into a budget bill. However, its treatment of owners who receive electronic communication is inconsistent with owners who receive communication through traditional means.

 

“Pennsylvania’s new statute pertaining to fiduciary accounts and IRAs states that if a holder doesn’t communicate with an owner through U.S. mail but rather electronic mail, then the holder is required to send an email notice to the owner,” says Karen Anderson, senior manager at KPMG. “If the email bounces back or there is no response, then the holder must send a due diligence letter via the U.S. Postal Service (USPS). If that mailing is returned as undelivered, the property would be reportable three years after the last owner activity. On the other hand, if the holder communicates with the owner of such accounts via US mail the account isn’t reportable until three years after the second returned USPS mailing. So, depending upon the holder’s method of communication with owners of these accounts, the Pennsylvania statute requires different due diligence treatment and a different dormancy trigger.”

 

Despite the recent decline in legislative activity, 2017 is likely to bring an immediate surge in new bills as a result of the ULC’s adoption of the 2016 UUPA.

 

“You could tell from recent activity that some states are aware of the language in the new UUPA,” Andre says. “Because the revised act addresses so many new areas addressed and is a true modernization of the act, I expect to see a flurry of activity resulting from it. States have been reviewing the act and planning what they’ll do, so there will likely be a lot of activity in early 2017.”

 

Some of the provisions that could gain traction address jurisdictional standards and triggers for property types not previously included in the act, such as health savings accounts and 529 college savings plans. The popularity among states of other areas remain less certain.

 

“It’s difficult to say whether state legislatures will adopt the transparency measures pertaining to audits that were built into the 2016 Uniform Unclaimed Property Act,” Anderson says. “Some of these provisions include reporting certain statistics regarding use of auditors. I’m not sure whether states will adopt those provisions as they may consider them too intrusive to their process.”

 

Litigation

While legislation slowed in 2016, noteworthy litigation didn’t show any signs of decreasing. Some of the most noteworthy areas being reviewed by ongoing and recently decided cases include:

  • Foreign property: JLI Invest S.A. et al. v. Cook et al. tackles the interplay between federal securities law, international law and Delaware state law. 
  • Derivative rights: “The Bed Bath and Beyond case will give some renewed emphasis to holders that they can assert derivative rights concepts in demonstrating that items states think are unclaimed property are actually not,” says Diann Smith, state and local tax attorney at McDermott Will & Emery. “So we could see similar types of litigation in other states, and derivative rights asserted in other property types beyond merchandise credits.”
  • Gift cards: Delaware ex rel. French v. Card Compliant LLC raises the question whether property holders can shift their liability via a contractual arrangement with another company.
  • Jurisdictional issues: Multiple cases involving MoneyGram consider whether certain unclaimed funds are governed by the general priority rules or by the specific rules of the Federal Disposition Act.
  • Benefit plans: “States frequently take the position that while the Employee Retirement Security Act of 1974 (ERISA) may preempt them from claiming property in ERISA-covered plans, they still have the authority to audit them,” Smith says. “So ERISA continues to be a problem that will likely play out via litigation.”
  • Savings bonds: States are increasingly looking to the U.S. government for unclaimed property funds in the form of unredeemed savings bonds. Especially noteworthy is Florida’s use of estimation to claim the United States owes the state $1 billion from unredeemed savings bonds.

 

As expected going into 2016, Temple-Inland Inc. v. Cook proved to be the most intriguing case of the year. On June 28, 2016, the U.S. District Court for the District of Delaware issued an opinion granting Temple-Inland’s request for summary judgment. The court called several aspects of Delaware’s audit practices “troubling.” On Aug. 5, 2016, Temple-Inland and the defendants filed a joint motion to dismiss the case, signaling a settlement and ending the dispute. 

 

Audits/VDAs

The full ripple effect from Temple-Inland on audits and estimation practices remains to be seen, but the settlement immediately triggered changes to Delaware’s voluntary disclosure agreement (VDA) program. Delaware reduced the look-back period for VDAs to 10 years plus dormancy, rather than the previous static date of 1996. The Delaware Department of Finance also is recommending changes to the state’s record revision provision for unclaimed property.

 

“There is more uncertainty now in terms of where things are going with both Delaware audits and the VDA program than I’ve seen before,” says Susan Han, principal, abandoned and unclaimed property consulting for Ryan. “This comes on the heels of the Temple-Inland decision and subsequent settlement, as well as changes we anticipate when the new legislative session begins in January.”

 

In the meantime, audit activity involving estimations in Delaware has essentially come to a halt, according to Troy Wangen, director of unclaimed property for True Partners Consulting LLC.

 

I think Temple-Inland is going to be game-changing for years to come,” he says. “Will other states look to benefit from this? Do holders look to benefit from it? Is there a potential for refunds? This all depends on what happens with estimation in that state in 2017. It could significantly change things.”

 

Another noteworthy audit trend is an increase in the number of audit firms in the unclaimed property marketplace. Particularly in Delaware, where a large percentage of audits have traditionally been handled by a single company, multiple firms are now auditing holders.

 

“Litigation shined a light on Delaware’s practice of giving most of its audit business to one firm,” Han says. “So the state enacted S.B. 11, which provides that no audit firm can be assigned more than 50 percent of all examinations commenced after Jan. 1, 2015. As a result, we are seeing both established and newer third-party auditors becoming much more active in unclaimed property.”

 

Looking Ahead

As 2017 unfolds, UPPO will continue to track and report on these and other developing trends. Watch this blog for updates and attend UPPO educational events to help you adapt to the ever-evolving unclaimed property environment.

 

 

Tags:  advocacy  audits  legislation  litigation  RUUPA  ULC  unclaimed property 

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Unclaimed Property Holiday Gift Guide

Posted By Administration, Friday, December 16, 2016

‘Tis the season for gift giving. Buying socks for your nephews and a scarf for your favorite aunt is the easy part. But what about the many people in your professional life who deserve a little holiday acknowledgment? UPPO is here to help make your last-minute gift buying a breeze. Following are suggestions for unclaimed property themed gifts for your professional peers, colleagues and acquaintances. The options presented in the unclaimed property gift guide are offered with tongue firmly planted in cheek. They are presented in the spirit of fun and without intent to offend.

 

Unclaimed Property Managers

Thanks to the popularity of services like Dollar Shave Club and Blue Apron, subscription services have sprung up for every imaginable type of product. Help your favorite unclaimed property managers stay alert throughout the reporting cycle with a coffee of the week subscription (even though they may appreciate a wine of the week subscription more).


Source: giphy.com

 

Unclaimed Property Consultants

Managing unclaimed property requirements and responsibilities can be taxing, so some companies turn to consultants to help make the process easier. Thank them by making their lives easier with the ultimate effort-saving gift—The Clapper.

Source: giphy.com

 

ULC Members

In July, the Uniform Law Commission published the Revised Uniform Unclaimed Property Act (RUUPA). Even if the RUUPA isn’t written exactly as you had hoped, you probably appreciate the commission members’ challenge of finding a reasonable middle ground and promoting a fair playing field for all stakeholders. You can help them fully embrace the role of referee as they work with other industries with the gift of a black and white striped suit or blazer.   

Source: halloweencostumes.com

 

Source: dhgate.com

 

State Legislators

In recent years, many legislators have expanded their states’ unclaimed property laws by including unredeemed gift cards. Show them you’ve been paying attention with this new twist on the traditional “charitable donation make in your name” greeting card: “In lieu of a traditional gift, we purchased and shredded a gift card for your favorite restaurant. We requested that, after the dormancy period, the restaurant escheat the full value of the card to the state in your honor.”

Source: giphy.com

 

State Administrators

State administrators are responsible for reuniting citizens with their property, but educating the general public about unclaimed property is a difficult task. People often ignore mailed notices, and newspaper ads reach only the 12 people who still subscribe to the newspaper. It’s enough to make an administrator want to scream. Help her turn that scream of frustration into a scream of productivity by giving her a megaphone. Used in a crowded public place, the megaphone is a retro-hip way for administrators to teach consumers about the potential goldmine of property awaiting them.

Source: makeagif.com

 

Third-Party Auditors

If you’ve been on the receiving end of a third-party audit, you know that auditors often take a “bigger-is-better” approach, expanding the scope by inviting other states to participate. So, this holiday season, give your favorite third-party auditor something truly appropriate—Chia Pet, the gift that grows.

Source: giphy.com

Tags:  unclaimed property 

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Overcoming record retention hurdles

Posted By Administration, Thursday, December 8, 2016

When it comes to record retention practices, many companies assume that if they follow the seven year IRS guideline that applies to many record types, they are adequately protected. However, that is not the case with unclaimed property records. In the event of an audit, unclaimed property holders need records to demonstrate compliance for a lookback period that often spans the dormancy period plus 10 years—sometimes longer, depending on the state conducting the audit.

 

Many state unclaimed property statutes provide scant retention requirements and, when addressed, often refer only to actual unclaimed property reports but not the backup detail for what went into those reports.

 

“You need to keep records showing that what you reported was reported properly, but you also need to keep records to prove that what wasn’t reported wasn’t unclaimed property due to the states,” says Ann Fulmer, director of Keane’s consulting and advisory services team.

 

As with many aspects of unclaimed property management, well-established policies, procedures and practices are essential to ensure property records and maintained and accessible. Unfortunately, developing and implementing these systems presents a few challenges.

 

Internal policies

Some legal departments strictly limit the records that can be maintained for more than seven years, as keeping them longer can increase liability. In addition, record storage can be expensive. Consider just one common property type—outstanding checks. A large company may have thousands of uncashed checks annually. For each year those records are maintained, the volume multiplies, requiring greater storage capacity.

 

“The auditors can only go back as far as you have researchable records,” Fulmer says. “If you have a solid, well-established record retention policy, the auditors cannot force you to create records you don’t have. If you only have records for seven years per your record retention policy, that’s how far their audit goes. They may request older years, but you’re limited by your record availability.”

 

The most noteworthy exception is the holder’s state of incorporation, which may estimate unclaimed property liability based on projections. Having detailed proof of a consistent reporting history can help provide protection in those cases.

 

“Make sure you keep all the detail that went into your unclaimed property reports, demonstrating you were reporting everything that needed to be reported to the proper states, including proof of payment,” Fulmer says. “That history can go a long way toward providing evidence that you’ve been in compliance even beyond your record retention policy.”

 

System conversions

As technology evolves, every company inevitably goes through system conversions that affect record-keeping. Often, all of the data will be maintained and management assumes that’s adequate. Unfortunately, the data is often not maintained in an easily accessible format.

 

“You may think you have sufficient records but don’t actually have access to what you need because of a system conversion,” says Jennifer Waryjas, associate with Reed Smith LLP’s state tax group. “When you need to access it, you may find that the people who know how to access it are no longer with the company, or the information is inaccessible because it exists in a system for which the company no longer has an interface.”

 

Record retention policies should specify not only that records are maintained when a system conversion occurs, but also the format and instructions for accessing them. Documentation is essential to ensure accessibility regardless of employee turnover.

 

Mergers and acquisitions

When a company merges with or acquires another business, unclaimed property issues are often low on the list of due diligence considerations. Unfortunately, neglecting the importance of unclaimed property during an acquisition can create significant challenges in the event of an audit. What records exist to prove the other entity properly reported its unclaimed property? Are those records easily accessible? A holder risks discovering in the midst of an audit that it doesn’t have substantial data and, thus, faces significant liability.

 

“As part of the due diligence process when acquiring another company, companies should consider potential unclaimed property exposure from the start,” Fulmer says. “You need to know what unclaimed property information is coming over with the new company and whether you’ll be able to easily access it.”

 

If a company addresses unclaimed property issues upfront and finds the acquisition doesn’t have adequate records or hasn’t been properly reporting, it can address how potential liability will be handled before the transaction is finalized. This can help limit related audit headaches down the road.

 

Proactive efforts

Developing and implementing record retention policies, procedures and practices takes a lot of effort and requires support and enforcement throughout the company. However, the immediate pain of going through the process can prevent much greater pain during an audit if you don’t.

 

“Address record retention issues now and you’ll be in a much healthier position down the road a few years when you get an audit notice,” Waryjas says. “It seems like a nonissue until you’re going through it. Then you realize what a huge issue it really is.”

 

To learn more about unclaimed property record retention, join Fulmer and Waryjas, as they lead the Living in the Past, Technology in the Present session at the 2017 UPPO Annual Conference. They will explore in greater detail the issues presented in this article along with related topics, including privacy issues and dealing with destroyed or lost data.

 

 

Tags:  audits  compliance  record retention  unclaimed property 

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