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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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Deadline Approaches for Converting Delaware Audits to VDAs

Posted By Administration, Wednesday, November 22, 2017

Under Delaware Department of Finance regulations that became effective on Oct. 11, 2017, unclaimed property holders that received an examination notice from the department on or before July 22, 2015, have the option to convert the audit to the state’s Voluntary Disclosure Agreement Program. The deadline for submitting the Notice of Intent to Convert Audit to VDA form is Dec. 11, 2017. Holders undergoing a securities examination are not eligible to convert.

 

Converting from an existing audit to a VDA holds several potential benefits for holders.

 

Waived interest and penalties

Delaware officials have stated that waiving the mandatory 25 percent interest charge and other penalties is intended to be a significant incentive for holders to come into compliance via the state’s VDA program.

 

Limited carryover of audit work

“The only aspect of the audit that will have precedential impact on the VDA is the scope of the examination,” said Kendall Houghton, partner with Alston & Bird. “That includes any determination by the Department of Finance and its contract auditors about which entities will come under review, and the applicable property types and years. Other than that, holders that convert to a VDA have the option to incorporate other aspects of work performed during the audit, but are not required to do so.”

 

This limited carryover of audit work has two noteworthy advantages to holders:

  1. They don’t have to start over, redoing every aspect of the audit. Holders that qualify for the VDA conversion have been under examination for at least two years and have likely dedicated significant resources to the process. They can choose to use completed work as they prepare their VDA analysis, submission and quantification of liability.
  2. They are not required to use the audit firm’s work papers and determinations made during the examination.

Closing and release agreement

Upon completing the VDA program, holders have the opportunity to secure a closing and release agreement from the secretary of state. That can be quite valuable, as it protects holders from liability for the period covered under the VDA, as long as there was no willful misrepresentation or fraud, and they meet future reporting requirements.

 

Flexibility

Holders that elect to convert their examinations to VDAs are not required to complete the VDA program. If they are unable to reach acceptable terms or anticipate that the results of an unclaimed property lawsuit may deem Delaware’s estimation practices unconstitutional, for example, holders may choose to withdraw from the VDA program. This gives them the option to challenge their liability or litigate it later, which would not be an option once the VDA closing and release agreement is finalized.

 

Control

Undergoing a self-directed review under the VDA process gives holders greater control of the process than completing an audit. The self-directed review is typically more targeted, freeing holders from overly broad information requests from the auditor. They also have the ability to set their own timelines.

 

“If you’re engaged in yearend closing and need to put the VDA process aside for a few weeks, you can do that without the constant tension of having to fulfill the auditor’s record requests,” Houghton said.

 

Relaxed review standards

The VDA’s review standards are generally less stringent than those imposed during an audit. For example, under an audit, checks voided after 30 days need to be researched and remediated. Under the VDA process, the standard increases to 90 days for voided checks. This standard is more in line with common business practices and is likely to generate a lower error rate for liability estimation.

 

“The remediation standards employed in the VDA program are more appropriate because the holder knows its policies and procedure, and is in the best position to assess whether an item on the books has been proven not to be unclaimed property,” said Houghton. “There is effectively a presumption in the audit process that anything on the books is unclaimed property, and the level of documentation required to rebut that presumption is more rigid.”

 

Greater cooperation

The VDA program is designed to give holders the opportunity to complete the self-directed examination, secure a release and move forward with proactive compliance. As such, even when issues between holders and the VDA administrators are contested, they are generally able to discuss, vet and settle the differences. Everyone involved typically approaches challenges with the common goal of collaborating on a solution.

 

Potential downsides

Despite the advantages available to holders through the audit-to-VDA conversion, opting to convert is not a clear-cut decision for everyone. As mentioned previously, upon execution of a closing and release agreement, holders forfeit the right to challenge the liability or later litigate it. In the event of a significant lawsuit that changes the unclaimed property audit landscape, holders that completed the VDA would not have the right to file a refund claim or dispute the estimated liability they paid.

 

For some holders that have substantially completed the audit process, the VDA process may represent an additional burden. Although not starting from scratch because they can use material from the examination period when preparing their VDA analysis, the self-directed review process still requires dedication of resources. A holder may decide that completing the audit process is more prudent than dedicating additional consultant, outside counsel and staff resources to the VDA program.

 

Finally, if the holder is subject to a multi-state audit, converting to a VDA in Delaware would not affect the audit from the other states. So, entering into the VDA could effectively shift the holder from a single process to multiple processes, posing potential resource issues.

 

The third option

In addition to completing the examination or converting to a VDA, holders may instead elect to convert to an expedited audit. Much like the VDA, this option includes a waiver of interest and penalties. However, very little information regarding the expedited audit process has been published, and the waiver is subject to the escheator’s determination that a holder cooperated with the auditor.

 

“The VDA and audit processes have been around a long time, but the expedited audit process is new and has a lot of unknowns,” said Houghton. “The administrative comments and guidelines don’t exist yet. That creates a lot of questions that aren’t yet answerable.”

 

For more information about Delaware’s VDA conversion initiative, refer to Delaware’s Convert Audit to a VDA web page.

Tags:  audits  Delaware  VDAs 

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Unclaimed Property News Roundup

Posted By Administration, Thursday, September 21, 2017

Unclaimed property has been in the headlines lately with a variety of stories appearing in local and national media outlets. Following is a recap of some of the most noteworthy reports.

 

Delaware’s pro-business image slides, in part from aggressive unclaimed property enforcement

On Sept. 11, 2017, Delaware Online published an article about a U.S. Chamber of Commerce study that dropped Delaware from the top state for business litigation to 11th. Among the reasons noted was the state’s aggressive enforcement of unclaimed property laws.

 

Unclaimed property takes center stage in Louisiana treasurer election

On Sept. 9, The Advocate published a lengthy article discussing how Louisiana’s former treasurer and current senator John Kennedy raised the profile of unclaimed property in the state. As a result, candidates for the upcoming treasurer election have made unclaimed property central to their campaign platforms.

 

Even celebrities appear on state unclaimed property lists

Reports in numerous media outlets, including WCVB TV, in the past few weeks have reported on members of pop group New Kids on the Block appearing on the Massachusetts unclaimed property list. Although celebrity unclaimed property reports are often a little hokey, they receive a lot of media and online attention, raising awareness of unclaimed property nationwide.

 

Texas unclaimed property rule changes receive coverage

On Aug. 30, Ignites, a Financial Times company, published an article discussing Texas unclaimed property rules that subsequently went into effect on Sept. 1. Commenting on behalf of UPPO, Kendall Houghton addressed the new Texas Designation of Representative form: “While there appears to be a maintenance requirement, there doesn’t appear to be a record retention period established through the form or, to my knowledge, by the comptroller’s office.”

 

Wall Street Journal looks at the JLI Invest unclaimed property case against Delaware

On Aug. 18, The Wall Street Journal published an article about the lawsuit brought by two French scientists against Delaware for seizing and selling their stock, considered by Delaware as unclaimed property. The value of the stock increased significantly after Delaware sold it but before the scientists learned their stock had been seized, causing them to lose millions of dollars, according to their complaint. The author of the WSJ article subsequently appeared on CNBC’s Closing Bell, discussing the article and the issues raised by the JLI case.

 

Bloomberg looks at issues with Delaware’s proposed unclaimed property rules

On Aug 14, Bloomberg BNA’s Salt Talk Blog published an article about Delaware’s work to develop new unclaimed property rules, required by S.B. 13. The article notes that many of the issues raised after Delaware released its previous version of the proposed rules remain present in the new version.

 

Tags:  Delaware  Louisiana  Texas  unclaimed property 

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2017 Unclaimed Property Legislative Roundup

Posted By Administration with contribution by Marcella Easly, senior compliance advisor at UPCR, Thursday, July 13, 2017

Across the nation, unclaimed property has been a popular topic for state legislatures this year. Although a handful of state legislatures are still in session, most have completed their work. Following is a brief summary of some of the most noteworthy unclaimed property bills that became law during the 2017 session. 

 

Delaware

Effective on Feb. 2, 2017, S.B. 13 adopts in substance many provisions from the 2016 Revised Uniform Unclaimed Property Act promulgated by the Uniform Law Commission. In addition, it adopts certain recommendations from the Delaware Unclaimed Property Task Force formed under Senate Concurrent Resolution No. 59 of the 147th General Assembly, and makes significant changes to the state's unclaimed property reporting process and compliance initiatives. More specifically, these changes include reducing the look-back period of all voluntary disclosure agreements and audits to 10 report years, and creating a 10-year statute of limitations for the state to seek payment of unclaimed property due to the state. In addition, this legislation aligns the state’s record retention requirement for companies with the statute of limitations and look back period, which brings State law into conformity with a majority of other states. This bill also offers any company currently under audit prior to July 22, 2015, the opportunity to convert their audit into a voluntary disclosure agreement by entering into the Secretary of State Voluntary Disclosure Agreement program. All companies who received a notice of examination and are currently under audit as of the effective date of this Act will have the opportunity to engage in an expedited audit review process. Finally, the bill mandates that interest be assessed on any late-filed unclaimed property, as a means to incentivize voluntary compliance. See previous UPPO’s May 4 blog post for more information about S.B. 13. 

 

Effective on June 29, 2017, S.B. 79 makes changes and corrections to SB 13. Among these changes, the amended bill ensures holders have sufficient time to comply with SB 13’s due diligence requirements with owners. It further clarifies that the state will indemnify and defend a holder against claims made by a foreign jurisdiction for property paid or delivered to the state escheator in good faith.

 

Idaho

Effective on July 1, 2017, H.B. 152 establishes an exemption from Unclaimed Property law for nonprofit corporations providing telecommunications service and delivery of electric power.

 

Illinois

Effective on Jan. 1, 2018, S.B. 9 creates the Revised Uniform Unclaimed Property Act. It adds language concerning definitions, applicability, rulemaking, and presumptively abandoned property. The bill also includes rules for taking custody of property that is presumed abandoned, reporting requirements, and required notice to property owners, among other provisions. The bill expressly excludes gift cards, loyalty cards and game-related digital content from property subject to escheat. However, it does not exclude gift cards from the definition of “stored-value cards,” which are subject to escheat, creating a potential conflict. The bill also specifies that virtual currency is subject to escheat. The state’s business-to-business exemption is not retained under the new bill.

 

New Hampshire 

Effective on Jan. 1, 2018, H.B. 473 increases the threshold above which merchants can sell gift cards with expiration dates from $100 to $250. The bill further clarifies that gift certificates of $250 or less shall not be considered abandoned property, and it revises the definition of gift certificate by removing the requirement that a gift certificate be in writing. The bill also provides that gift certificates and store credits remitted to the state prior to Jan. 1, 2018, must remain in the custody of the state until returned to the owner.

 

South Dakota

Effective on March 10, 2017, S.B. 34 revises provisions related to securities held as unclaimed property. It requires the state treasurer to sell all stocks, bonds, and other negotiable instruments within 90 days of confirmed receipt, unless the property is on an open claim.

 

Effective on July 1, 2017, H.B. 1081 revises provisions for establishing a trust for a mineral owner who cannot be located. It provides that a person or entity holding interest in a tract of land may petition a county court to create a trust in favor of an undetermined owner of a mineral interest in that tract of land. It further provides conditions for the creation and administration of such a trust.

 

Tennessee

Effective on July 1, 2017, H.B. 420 repeals and reenacts the Uniform Unclaimed Property Act. It includes dormancy periods, reporting and due diligence requirements, and abandoned life insurance provisions, among other measures. The bill requires the treasurer to sell or liquidate securities between eight months and one year after receiving the security. 

 

Texas 

Effective on Sept. 1, 2017, S.B. 561 relates to unclaimed life insurance and annuity contract proceeds. Among its provisions, the bill requires an insurer to periodically compare its applicable in-force life insurance policies, annuity contracts, and retained asset accounts against a Death Master File. In the event of a match, insurers are required to complete a good faith review of the situation, and if proceeds may be due, to conduct outreach to beneficiaries within 90 days and provide assistance in making a claim. The bill further requires an insurer to report and deliver unclaimed proceeds to the comptroller of public accounts.

 

Effective on Sept. 1, 2017, H.B. 2964 adopts a Senate amendment and provides that a holder of mutual fund shares must notify an owner at initial purchase that the owner may designate a representative to receive a notice of abandonment.

 

Utah

Effective on May 8, 2017, H.B. 175 repeals and reenacts the Revised Uniform Unclaimed Property Act. Among its provisions, the bill revises presumptions of abandonment, amends reporting procedures, and addresses the duties of a holder of abandoned or unclaimed property.

 

Effective on May 8, 2017, H.B. 42 makes comprehensive revisions to insurance law. Among other changes, the bill amends definitions under the Unclaimed Life Insurance and Annuity Benefits Act by removing the definition of "Knowledge of death."

 

For the latest information about these and other noteworthy unclaimed property bills, visit UPPO’s govWATCH website. 

 

About the contributor 

Marcella Easly, senior compliance advisor at Unclaimed Property Consulting & Reporting (UPCR), contributes to UPPO’s regular legislative update blog posts. Easly has more than 30 years of unclaimed property experience with special focus in state legislative tracking and resolving client-state advocacy issues. She was Unclaimed Property Manager for the State of Oregon for 14 years.  She was active in the National Association of Unclaimed Property Administrators (NAUPA), serving as president, and regional vice president.  She was instrumental in the creation of the NAUPA property type reporting codes.  She has been with UPCR for 11 years, and has been active in UPPO for more than 13 years.   

 

 

Tags:  Delaware  Idaho  Illinois  legislation  New Hampshire  South Dakota  Tennessee  Texas  unclaimed property  Utah 

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Title: A look at Delaware’s statute recognizing first priority states’ exemptions under S.B. 13, part 2

Posted By Mark Watters, Thursday, June 29, 2017

Part 1 of this article provided an overview of Delaware’s prior application of the priority rules and an in-depth explanation of what constitutes an exemption under §1141(b).

 

How should holders manage these “exemptions” under §1141(b)?

Until holders gain greater clarity through statements of policy, regulations and common law, application to the previous examples will remain a business decision for holders seeking to balance aggressive and conservative practices. Too aggressive, and holders face potential audit exposure; too conservative, and holders may be remitting properties it need not immediately forfeit. 

 

Each holder needs to review its own practices under its unclaimed property policies, determine a logical and supportable position, and memorialize that position for support and reference years into the future. 

 

Delaware may—in the interest of clarity, certainty, better holder compliance and the resulting ease of auditing for holders and state agents—provide answers to these questions; in the previous examples there need not be any lack of clarity, at least in the general application. Such leadership would be welcomed by auditors and holders alike, and would create an open dialogue should disagreements arise. Such policy would allow holders greater ability to manage their risks and create an environment for better compliance.

 

Absent these answers, holders will need to take a common sense approach to these issues as they arise. Holders should have knowledge and understanding of its facts and the “exemption” it contemplates taking, record that for future reference, and review its policies periodically to determine if they are still valid. Failing to do so in the context of unclaimed property compliance compounds the issues and potential exposure or complexity of the holder’s redemption. 

 

Some considerations:

  • Risk/benefit. Holding properties under a dubious or questionable “exemption” or factual basis may not be worth any benefit over that of the risk involved. This risk is not only a financial one, but one which impacts good relations with customers, suppliers, and the public perception and image of the holder.
  • Costs of property maintenance and preservation. Some properties are just not worth the costs of maintenance and preservation. Escheatment provides an answer. By way of example, some states have a business-to-business exemption (b2b) that provides an exemption by deferral, whereby once the relationship between the holder and owner ends, the property must be escheated. Under such circumstances, the holder might do well to try settling the obligation with the owner, but thereafter, forego the deferral exemption and report the property at first opportunity. An “exemption” need not be taken and there are generally no penalties for early reporting of such properties. 
  • Costs of retaining records. Increasingly, states are reviewing records of unreported properties and documentation as to why they were not reported. This has created a greater burden on holders to maintain, preserve and index records for future reference and audit support. For exempt properties, holders have a greater burden to monitor laws to ascertain changes or eliminations of such “exemptions,” which need not be so closely reviewed if such properties are escheated. Many would agree that growing unclaimed property record maintenance has made the task more onerous and the costs of software and means for individual property record retrieval more costly and time-consumptive. Escheatment and passive record retention may be a better business decision than active maintenance of an extensive pool of active property records. 
  • The “sleep at night” test. Related to the risk/benefit analysis, does it make sense to create additional stress by holding properties at risk of audit? Escheating “at risk” properties helps to limit that stress and frees up company resources and personnel for value added pursuits.

Conclusion

The Delaware exemption and its application will be developed as time and opportunities allow. This recognition of other jurisdictions’ exemption is a welcome change to unclaimed property compliance. Let’s hope other states follow Delaware’s example as they review and enact their own updates from the current uniform act. 

 

There remain certain areas that would benefit from clarification and cleanup, some of which are discussed in this article. As compliance practitioners, we must carefully analyze each circumstance and determine whether we should apply the “exemption” to each factual pattern and each jurisdiction’s laws, regulations, and policies as we understand them. 

 

Remember that taking unclaimed property “exemptions” of any nature is not required; they are discretionary. Decisions about such require careful consideration of holder legal responsibility, and business purposes and goals.

 

About the Contributor

Mark Watters is technical director, unclaimed property, for DuCharme, McMillen & Associates Inc.

 

Disclaimer: Neither UPPO nor DMA, or any of their affiliated or related entities, by means of this summary, is rendering business, financial, legal, tax, reporting or compliance or other professional advice or services. This blog post is not a substitute for such professional advice.

Tags:  compliance  Delaware  priority rules  unclaimed property 

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A look at Delaware’s statute recognizing first priority states’ exemptions under S.B. 13, part 1

Posted By Mark Watters, Thursday, June 22, 2017
Updated: Thursday, June 29, 2017

One of the key provisions of Delaware’s S.B. 13, 149th General Assembly (the 2017 revision of its unclaimed property act), is Del. Code Ann., tit. 11, §1141(b), honoring exemptions of all first priority jurisdictions.

 

Formerly, Delaware was known to take properties exempted by the first priority jurisdiction based upon its interpretation of the priority rules (discussed below). As a majority of business associations are incorporated or formed in Delaware, this was a significant frustration of purpose for many other jurisdictions’ exemptions and provided a sizable windfall to Delaware. 

 

The new Delaware statute now maintains the exemption of the state of first priority, a reversal of the former Delaware common law practice. All the same, is the new “broad brush” Delaware exemption as it appears, or will it be restricted in practice by the state escheator?

 

Priority Rules and Prior Delaware Application

Under Texas v. New Jersey, 379 U.S. 674 (1965), the U.S. Supreme Court settled competing claims to property, creating a set of priority rules between competing state claims to properties. Under those priorities, the state of the property owner’s last known address has first priority to take the property. The second priority, which applies if the state of first priority takes no claim to the property, fell to the state of the holder’s incorporation (and now, formation for unincorporated business associations). The third priority, which is less well defined and which is rarely applied, is essentially any state with an economic interest, such as the jurisdiction where the original obligation arose. 

 

Under these common law rules, Delaware has historically benefited by taking properties with no known owner and address, foreign properties (that had no “state” of last address) and properties that were not escheatable to the state of first priority for any reason.

 

Del. Code Ann., tit. 11, §1141(b) (S.B. 13, 149th General Assembly)

Under its new statute, it appears that this substantial source of Delaware’s historic unclaimed property has been proactively eliminated; properties, once exempt in the jurisdiction of first domicile but taken by Delaware, may no longer be escheatable in Delaware under Del. Code Ann., tit. 11, §1141(b):

 

(b) Property is not subject to custody of the State Escheator under subsection (a) of this section if the property is specifically exempt from custodial taking under the law of this State or the state of the last-known address of the owner.

 

Under previous application, other states’ exemptions were frustrated by requiring holders incorporated in Delaware to escheat properties under the second priority.

 

This new Delaware statute raises several complex issues of application and definition, which will be resolved over time through regulation, policy, and practical application:

  • What constitutes an “exemption”?
  • How should holders manage these exemptions?

This article seeks to create awareness of these questions for further discussion.

 

What constitutes an “exemption” under §1141(b)?

There is no statutory definition of “exemption” under S.B. 13, so initially state regulation, policy statements, and audit practice will provide parameters. Guidance is promptly needed, since many potential “exemptions” represent substantial and growing amounts on the records of holders and, thus, potential significant exposure.

 

The meaning of “exemption” should apply to any specifically-identified by that term in the law. Beyond the use in statutes and common law of that exact word, there are other statutory constructions that arguably act as exemptions, but are not so named or act as property value reductions only. These terms include:

  • Exceptions. Exceptions differ from exemptions primarily by how they arise. While an exemption recognizes that such properties would generally be escheatable, by affirmative statutory construction an exception is created by carving out that property type from the general statutory base. There are two types: Those created by definition restriction; and those created by statutes of application. The former will be found in statutes of definition, typically in that for “property”; the latter in statutes requiring general escheatment of a property type “except for” certain properties falling under a particular fact pattern or other condition. These differences are not important to our survey; each can be identified by the word “except” and its derivatives in the statutory or common laws proper;
  • Minimal value “exemptions.” Minimal value exemptions restrict the escheatment of properties exceeding a certain minimal value; 
  • Business sector exemptions. A few jurisdictions have exemptions based solely on the holder’s industrial sector, applicable to certain property types;
  • De facto exemption through superseding statutes. Federal and state laws, especially in the consumer protection, banking, insurance and commercial sectors, superseding unclaimed property law;
  • Deferral “exemptions,” where the holder need not report property until there is a clean break in overall relationship with the (typically business) owner; and
  • Reductions and deductions. These are reporting value adjustments recognizing and relieving duties and burdens imposed on holders. Typically, these are cost reimbursements, actual or computed, for the management of properties, particularly for performance of due diligence and preservation of properties and their maintenance on the books and records of the holder. These reductions and deductions may apply to both holders and state property administrators, the latter as compensation for property advertising and preservation. 

These are discussed in the context of Delaware’s statute below. 

 

Exceptions in state codes are clearly purposed to withdraw certain properties from escheatment in their jurisdictions just like exemptions. Unlike exemptions, these generally are not discretionary but mandatory. One would hope by application and intent exemptions and exceptions would receive equal treatment.

 

Partial exemptions. Several states provide a partial exemption, typically exempting minimal values of specific properties; higher property values are fully subject to escheatment. This issue is very hard to predict, as minimal values under the reporting threshold but having a single owner could be consolidated by Delaware to pass the threshold of such minimal values, and even if analyzed alone, might not rise to the level of “exemptions” under Delaware’s statute. 

 

Business sector exemptions. A few states create special exemptions for cooperatives, certain preferred business sectors, and similar holder groups. These exemptions are usually also limited to certain property types. By practical application these should be recognized as exemptions

 

De facto exemption through superseding statutes. There are many areas where federal and state laws supersede those for unclaimed property; many state laws are universal. These include life insurance, gift cards and certificates, commercial paper, and many others. Such statutory preemption should expect to be recognized. Common law (through litigation) recognizes other circumstances of preemption, such as U.S. savings bonds, although the case law may not be recognized until litigated in courts of local jurisdiction. 

 

Deferral “exemptions.” These are not true exemptions, but rather stay or delay escheatment until certain conditions are met, typically when the holder breaks connection with the owner. While these may be titled or described as “exemptions”, these are rightly deferrals, where the state of first priority delays (“defers”) reporting until after a break between the holder and owner. These properties may be subject to Delaware escheatment, especially considering the 10-year statute of limitations (Del. Code Ann. tit. 11, §1156(b)), and the closing door of opportunity; likewise, Delaware could honor the deferral and allow the jurisdiction of first priority to take when it is appropriate to do so.

 

Reductions and deductions. These are generally modest amounts to recompense the holder for costs associated with property management and reporting compliance. One might expect Delaware to honor such allowances of its sister states. However, there is no clear statutory requirement that it do so except through the statutory authority cited in this paper. This author is unaware of any instance where Delaware has historically pursued such allowances under the old law. 

 

Holders should be careful to recognize that any applied “exemption” does not extinguish its obligations to the property’s owner; rather, exemptions only relieve the holder from reporting and remitting the property to the appropriate jurisdiction. Obligations to the property’s owner are never relieved. 

 

The ultimate duty of all holders is to return property held to its rightful owner or report and remit it to the state. In addition, rolling such properties back into P&L may violate accounting standards that are beyond unclaimed property laws. Thus, other than the important consideration as to who should have the right to hold and have use of the property until redemption, there is no permanent value to its possession. 

 

Part 2

Part 2 of this article examines how holders should manage these exemptions.

 

About the Contributor

Mark Watters is technical director, unclaimed property, for DuCharme, McMillen & Associates Inc.

 

Disclaimer: Neither UPPO nor DMA, or any of their affiliated or related entities, by means of this summary, is rendering business, financial, legal, tax, reporting or compliance or other professional advice or services. This blog post is not a substitute for such professional advice.

Tags:  Compliance  Delaware  priority rules  unclaimed property 

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