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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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Tennessee Reduces Dormancy and Lookback Periods, Adds Requirements

Posted By Administration, Thursday, August 10, 2017

Among the first states to pass a version of the Revised Uniform Unclaimed Property Act this year was Tennessee. On May 25, 2017, Tennessee Gov. Bill Haslam signed H.B. 420 into law, effective July 1, 2017. The new law includes several substantial changes to the state’s unclaimed property requirements. Noteworthy provisions include:

 

New property types: Among the new property types addressed in H.B. 420 are health savings accounts (HSAs) and stored value cards. HSAs are presumed abandoned if unclaimed three years after the earlier of either the date distributions must begin to avoid tax penalty or 30 years after the account was opened. Stored value cards (other than payroll or gift cards) are presumed abandoned five years after the later of: Dec. 31 of the year in which the card was issued or funds were last deposited; the most recent indication of owner interest in the card; or a verification of the balance by or on behalf of the owner. 

 

Due diligence: Holders must perform due diligence for property valued at $50 or more. Notices must be sent to apparent owners by first-class mail between 180 days and 60 days before the unclaimed property report is filed. Owners who have consented to receive electronic communications must be sent the notice by both first-class mail and email unless the holder believes the email address is invalid. 

 

DMF matching requirement: The new law specifies that life insurers must perform searches of the death master file and comply with the Unclaimed Life Insurance Benefits Act. 

 

Dormancy periods: Most property type dormancy periods have been reduced from five years to three years under H.B. 420.

 

Audit lookback period: For audits in Tennessee, the lookback period has been reduced from 10 years to five years. 

 

Record retention: Holders are required to retain records for 10 years after the unclaimed property report was filed or was due to be filed. 

 

Promulgation of examination rules: The new law specifies that the state treasurer should develop rules for examinations, including procedures and standards for estimation, extrapolation and statistical sampling.

 

Sale of securities: H.B. 420 requires the treasurer to sell a security between eight months and one year after receiving it and giving the apparent owner notice. If the treasurer sells the security within six years, and a valid claim is filed before the six-year period expires, the owner will be entitled to receive a replacement of the security or its market value plus interest.

 

Informal conference provision: This law establishes provisions for an informal conference in situations where an examination results in a determination that a holder has failed to pay or deliver reportable property to the treasurer. It also allows for judicial review of the treasurer's decision. 

 

Exemptions: The law retains the state’s business to business and gift card exemptions. 

 

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

 

Tags:  audits  DMF  dormancy periods  due diligence  record retention  RUUPA  securities  Tennessee  unclaimed property 

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Illinois Passes New Unclaimed Property Act, Repeal Effort Underway

Posted By Administration, Thursday, July 20, 2017

On July 6, 2017, Illinois budget bill S.B. 9 became law after the House voted to override the governor’s veto. Among the provisions added to the bill shortly before passage was the Illinois Revised Uniform Unclaimed Property Act, which repeals the state’s current unclaimed property statute and replaces it with new language. 

 

S.B. 9’s unclaimed property provisions become effective on Jan. 1, 2018. However, a movement to repeal the Illinois RUUPA is already underway. 

 

Illinois RUUPA

Among the Illinois RUUPA provisions that are most noteworthy for holders are:

  • The new statute’s definition of escheatable “property” specifically excludes game-related digital content, loyalty cards and gift cards. The definition of “stored-value card” specifically excludes loyalty cards and game-related digital content but includes gift cards. Because stored-value cards are escheatable property, these opposing definitions present an obvious conflict for holders that deal with gift cards. 
  • The new statute defines “virtual currency,” and includes it within the list of escheatable property.
  • Tax-deferred accounts are considered abandoned under the new statute three years after either the required distribution date for avoiding tax penalties, or the 30th anniversary of the account’s opening date—whichever is earlier. Earlier abandonment dates are specified for deceased owners of such accounts. The statute specifically includes health savings accounts in the tax-deferred account provision. 
  • Similarly, the statute includes detailed provisions regarding custodial accounts for minors.
  • Holders are required to maintain records for 10 years. Retained records must include unclaimed property report information; the date, location and circumstances that led to the property rights; property value; last-known owner address; details for items that were not reported as unclaimed; and details related to money orders, traveler’s checks and similar instruments. 
  • The statute incudes a “transitional provision” that requires holders to file an initial report for property that was not previously reportable, but is reportable under the new statute for a period of five years from the effective date (Jan. 1, 2018). 
  • The state’s current business-to-business unclaimed property exemption is excluded from the new law. 

 

Repeal Effort

Before S.B. 9 passed, efforts to repeal the Illinois RUUPA provisions were already underway. On July 3, 2017, Rep. David McSweeney introduced H.B. 4078, which specifies that if S.B. 9 becomes law, the Illinois RUUPA provisions contained in S.B. 9 will be repealed, effective immediately. If passed, the state’s current unclaimed property law, the Uniform Disposition of Unclaimed Property Act, would remain in effect. Before the Illinois legislature’s recess, 19 representatives signed on as co-sponsors of the bill. 

 

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

 

 

Tags:  B2B exemption  gift cards  Illinois  RUUPA  unclaimed property  virtual currency 

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S.B. 13 makes sweeping changes to Delaware’s unclaimed property statutes

Posted By Administration, Thursday, February 16, 2017

On Feb. 2, 2017, Gov. John Carney signed Delaware S.B. 13 into law, significantly updating the state’s unclaimed property statutes. Many of the changes mirror the 2016 Revised Uniform Unclaimed Property Act (RUUPA), and others appear to respond to issues raised by the Temple-Inland case. The new law is intended to “bring greater predictability, efficiency and fairness to the state’s unclaimed property reporting process and compliance initiatives.” Following is a summary of several of the law’s most noteworthy provisions.

 

Lookback, Record Retention and Statute of Limitations

S.B. 13 reduces the lookback period for both audits and voluntary disclosure agreements (VDAs) to 10 years plus dormancy. It also defines an express record retention period of 10 years from the date a holder submits a report. The statute of limitations is now 10 years from the date the duty arose, whether or not the holder reported the property. The previous statute of limitations, although shorter, began to run from the time the holder reported the property.

 

Estimation Methodology

The new law mandates that the secretaries of finance and state develop estimation regulations by July 1, 2017. They must include permissible base periods; items to be excluded from estimation calculation; aging criteria for outstanding and voided checks; and a definition of what constitutes “complete and researchable records.”

 

Audit Conversion

Under the new law, all holders currently under audit may convert to a two-year accelerated audit. Holders under audit as of July 22, 2015, may convert to a VDA program. Holders have until 60 days after the promulgation of the new estimation regulations to decide whether to convert to an accelerated audit or VDA program. Interest and penalties will be waived if conversion is made. Holders remaining in the audit will be subject to mandatory interest that is waivable only up to 50 percent.

 

Subpoena Authority

Provisions of the new law give the state escheator the power to issue an administrative subpoena and the ability to seek enforcement of an administrative subpoena in the Court of Chancery. These provisions appear to address issues raised by Delaware Department of Finance v. Blackhawk Engagement Solutions.

 

Judicial Review

Among the new provisions adopted in Delaware is a process for appeal by holders to the Delaware Court of Chancery, replacing the previous multi-step administrative review process. Under the new appeal process, holders have the ability to challenge the state escheator’s determination of liability. The court’s standard of review is deferential to the state escheator regarding factual determinations, but errors of law will be reviewed de novo. The judicial review provision also expressly gives the Court of Chancery the authority to review questions of state or constitutional law related to the examination. This provision appears to be a response to the Temple-Inland case.

 

Indications of Owner Interest

S.B. 13 adds a specific list of owner activities that prevent running of the dormancy period. Indications of the owner’s interest in property includes:

  • A written or oral communication by the owner to the holder or agent of the holder concerning the property or the account in which the property is held.
  • Presentment of a check or other instrument of payment of a dividend, interest payment or other distribution.
  • Accessing the account or information concerning the account, or a direction by the owner to increase, decrease or otherwise change the amount or type of property held in the account.
  • Payment of an insurance policy premium with some exceptions.

The new law also specifies that if an owner has more than one investment or account with a holder, an indication of interest in one investment or account is an indication of interest in all of those accounts.

 

Knowledge of Death

The new law adopts the “knowledge of death” concept as a dormancy trigger for life insurance proceeds. “Knowledge of death” may be identified through any source, such as declaration of death, a death certificate or the comparison of the holder’s records against the Social Security Administration’s Death Master File.

 

Priority Rules

For the first time, the Delaware unclaimed property law includes a codification of the U.S. Supreme Court’s priority rules. It expressly prohibits Delaware as the state of domicile under the second priority rule from taking property into custody that is exempted in the first priority rule state. It also allows the state of domicile to claim foreign-address property but excludes property claimed under foreign law.

 

Owner Address

S.B. 13 adopts portions of RUUPA’s definition of an owner’s “last-known address.” The last-known address of an owner is defined as “a description, code or other indication of the location of the owner on the holder’s books and records that identifies the state of the last known address of the owner.”

 

Disposal of Securities

The new law specifies that the state escheator shall sell or dispose of securities on any established stock exchange or by such other means as soon as the escheator deems it feasible after the delivery. The escheator may not sell a security listed on an established stock exchange for less than the price prevailing on the exchange at the time of sale. The escheator may sell a security not listed on an established exchange by any commercially reasonable method.

 

S.B. 13 provides for indemnification of security owners for 18 months. The escheator will provide either a replacement security or the market value of the security at the time the claim is filed if the owner comes forward with that 18-month period.

 

Gift Cards

For the first time, Delaware’s statute defines “gift cards,” “stored value cards” and “loyalty cards.” Gift cards and stored value cards remain escheatable after five years of inactivity. The state retained its unique profit retention provision defining the amount unclaimed as “the amount representing the maximum cost to the issuer of the merchandise, goods, or services represented by the card.” S.B. 13 adds “Goods” and “Services” into the mix, as old statute only provided exemption for “maximum cost to issuer of merchandise represented by the card.” Loyalty cards are expressly exempt.

 

Holders are prohibited from transferring their unclaimed property liability or obligation, except to a parent, subsidiary or affiliate. This provision affects third-party, unrelated companies that issue gift cards on behalf of a business and appears to address some of the uncertainty resulting from the Card Compliant qui tam litigation.

 

Compliance Review

Another new provision in the law permits the state escheator to conduct a “compliance review” if the escheator believes a filed report was inaccurate, incomplete or false. The compliance review is limited to contents of report and all supporting documentation. The escheator is required to adopt rules governing the procedures and standards for compliance reviews, but no timeline was included in the statute.

 

Application of the New Law

S.B. 13 represents a major change in Delaware’s unclaimed property practices with many positive developments for holders. They include reduced lookback, clear record retention period, estimation regulations, statute of limitations regardless of prior reporting compliance, direct appeal to Court of Chancery, new definitions and new exemptions.

 

As with any new law, it remains to be seen how provisions will be interpreted and applied. Holders await the regulations still in development regarding audit conversions to fast-track audits and VDAs, and the new compliance review provision. Clarification from Delaware will help holders make informative judgments about whether to convert current audits into VDA or fast track audits, and whether other changes to their unclaimed property practices are warranted.

 

Tags:  audits  Delaware  estimation  gift cards  RUUPA  unclaimed property 

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State Legislatures Reconvene, Immediately Take up Unclaimed Property Issues

Posted By Administration, Monday, January 30, 2017

Reconvening earlier this month, state legislatures are wasting no time considering new unclaimed property legislation, including language from the Revised Uniform Unclaimed Property Act. Following are summaries of several of the most noteworthy bills UPPO is tracking.

 

Arkansas

H.B. 1142 extends the presumed date of abandonment for securities from five to seven years from any of the following:

  • The date of most the recent dividend, stock split or other distribution unclaimed by the apparent owner;
  • The date of second mailing of a statement of account or other notification or communication that was returned as undeliverable, or after the holder discontinued mailings, notifications or communications to the apparent owner;
  • The date that the security holder or payee is presumed lost or unresponsive as it existed on Jan. 23, 2013.

The bill also includes new provisions requiring the security holder to liquidate the security before remitting it to the administrator. The bill was referred to a Senate Committee on Jan. 23.  

 

Delaware

Highly anticipated legislation since last summer’s Temple-Inland summary judgment and settlement, S.B. 13 adopts provisions from the 2016 Revised Uniform Unclaimed Property Act. It also adopts certain recommendations from the Delaware Unclaimed Property Task Force and makes significant changes to the state's unclaimed property reporting process and compliance initiatives.

 

These changes include reducing the look-back period for 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 mirrors laws in a majority of other states.

 

S.B. 13 also offers any company currently under audit the opportunity to convert their audit into a voluntary disclosure agreement. Since July 22, 2015, Delaware law has allowed companies to enter into a VDA before going through an audit. This change provides the VDA option for companies whose audits began before July 22, 2015, and are still in process. It also gives all companies that received a notice of examination who are currently under audit on the bill’s effective date the opportunity to engage in an expedited audit review process.

 

The bill addresses the state’s estimation practices for audits and VDAs, requiring the secretaries of finance and state to develop by July 1, 2017, regulations for estimation base periods, excluded items, aging criteria for outstanding and voided checks, and the definition of “complete and researchable records.”

 

Finally, the bill mandates that interest be assessed on any late-filed unclaimed property, as a means to incentivize voluntary compliance. The bill quickly made its way through the legislature, and was sent to the governor on Thursday, Jan. 26 for signing.

 

Nebraska

The unicameral legislature in Nebraska is considering a pair of unclaimed property bills. L.B. 137 adopts the Unclaimed Life Insurance Benefits Act. It requires an insurer to compare its policies and retained asset accounts against a death master file to identify possible matches of its insured at least a semi-annually. The bill outlines requirements in the case of a match or potential match, as well as procedures for group life insurance. A hearing is scheduled for Jan. 30.  

 

L.B. 141 adopts the Revised Uniform Unclaimed Property Act. Among relevant provisions, the bill establishes various dormancy periods and due diligence requirements. It exempts gift cards without expiration dates and fees and establishes a three-year dormancy period for returned merchandise credits and gift cards with fees. The bill also outlines the state treasurer’s responsibilities regarding unclaimed property and provides for holder reimbursement where appropriate. It provides in certain circumstances for the right of another state to take custody of unclaimed property. The bill is still awaiting to be scheduled for a committee hearing.

 

New York

S.B. 1689 prohibits gift card expiration dates and dormancy service fees unless it meets four conditions:

1.       The remaining value of the gift card is $5 or less each time the fee is assessed;

2.       The fee does not exceed $1 per month;

3.       There has been no activity on the gift card for 24 consecutive months; and

4.       The holder has the ability to reload or add value to the gift card.

 

The bill also requires retailers to redeem gift certificates of $10 or less for cash at the consumer's request. The bill was referred to the consumer protection committee.

 

Oregon

S.B. 113 requires the provider of goods and services identified on a gift card to transfer to the Department of State Lands the remaining balance of any gift card after five years of inactivity from the date of the last purchase using that gift card. The bill is currently in committee.

 

South Dakota

S.B. 34 revises provisions related to securities held as unclaimed property. The bill 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. The bill was referred to a House Committee on Jan. 20.

 

Utah

H.B. 42 makes comprehensive revisions to the state’s 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.” The bill saw its third hearing in the House on Jan. 25.

 

UPPO continues to monitor all of the pertinent bills affecting members. For the latest information about these and other noteworthy unclaimed property bills, visit UPPO’s govWATCH website.

 

Tags:  audits  death master file  insurance  RUUPA  securities  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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