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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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2017 Fall Reporting Checklist Part 3 (Mississippi – Rhode Island)

Posted By Administration, Tuesday, August 22, 2017

Fall reporting season is again upon us. Most U.S. states require holders to file reports by either Oct. 31 or Nov. 1. Following are reporting deadlines for these states, along with helpful links. We have also included information submitted to UPPO by unclaimed property administrators in response to a recent survey requesting updated reporting information. This list is not exclusive to a specific holder industry, so please check the states’ websites for information on industry-specific reporting information and deadlines. 

 

Part 1 covered Alabama through Hawaii.

Part 2 covered Idaho through Minnesota.

Part 3 covers Mississippi through Rhode Island.

Part 4 will cover South Carolina through Wyoming.

 

 

Mississippi

Report due: Nov. 1, 2017

Extensions: Extensions may be requested.

 

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

Mississippi holder resources

 

Missouri

Report due: Nov. 1, 2017

Extensions: Extensions may be requested in writing at least 30 days before the reporting due date.

 

Contact: Scott Harper: Scott.Harper@treasurer.mo.gov or (573) 751-2082

Missouri holder resources

 

Montana

Report due: Nov. 1, 2017

Extensions: Extensions may be requested.

 

Contact: UnclaimedProperty@mt.gov or (866) 859-2254

Montana holder resources

 

Notes from UPPO’s state administrator survey:

  • Instruction manual/handbook has been updated in the past three months.

 

Nebraska

Report due: Nov. 1, 2017

Extensions: Extensions may be requested.

 

Contact: Email form or (402) 471-8497 or (877) 572-9688

Nebraska holder resources

 

Nevada

Report due: Oct. 31, 2017

Extensions: Extensions may be requested.

 

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

Nevada holder resources

 

New Hampshire

Report due: Nov. 1, 2017

Extensions: N/A

 

Contact: ap@treasury.state.nh.us or (603) 271-2619

New Hampshire holder resources

 

New Jersey

Report due: Oct. 31, 2017

Extensions: Extensions may be requested.

 

Contact: Email form or (609) 292-9200

New Jersey holder resources

 

Notes from UPPO’s state administrator survey:

  • Instruction manual/handbook has been updated in the past three months.
  • Paper reports are no longer accepted. Please use the manual report option in the HRS Pro online reporting.
  • Report file type change: Online reporting via New Jersey UPA online holder reporting tool.

 

New Mexico

Report due: Nov. 1, 2017

Extensions: Extensions may be requested.

 

Contact: (505) 827-0767 or (505) 827-0668

New Mexico holder resources

 

Notes from UPPO’s state administrator survey:

  • Please take care to use correct ZIP codes and report to the correct state.

 

North Carolina

Report due: Nov. 1, 2017

Extensions: Extensions may be requested.

 

Contact: unclaimed.property@nctreasurer.com or (919) 814-4200

North Carolina holder resources

 

Notes from UPPO’s state administrator survey:

 

North Dakota

Report due: Nov. 1, 2017

Extensions: Extensions may be requested in writing before the report due date.

 

Contact: Email form or (701) 328-2800

North Dakota holder resources

 

Notes from UPPO’s state administrator survey:

  • Instruction manual/handbook has been updated in the past three months.

 

Ohio

Report due: Nov. 1, 2017

Extensions: Extensions may be requested.

 

Contact: UnfdClaims.UnfdClaims@com.ohio.gov or (614) 466-4433

Ohio holder resources

 

Oklahoma

Report due: Oct. 31, 2017

Extensions: Extensions may be requested in writing on company letterhead before the report due date.

 

Contact: Kathy Janes: Kathy.Janes@treasurer.ok.gov or (405) 521-4275

Oklahoma holder resources

 

Oregon

Report due: Nov. 1, 2017

Extensions: Extensions may be requested.

 

Contact: holder@dsl.state.or.us or (503) 986-5200

Oregon holder resources

 

Notes from UPPO’s state administrator survey:

 

Rhode Island

Report due: Nov. 1, 2017

Extensions: Extensions may be requested in writing before the report due date.

 

Contact: ups@treasury.ri.gov or (401) 462-7676

Rhode Island holder resources

 

For detailed information about reporting deadlines, dormancy periods, due diligence requirements, exemptions and deductions, electronic filing and much more, UPPO members can refer to the Jurisdiction Resource Guide

 


Tags:  fall reporting  unclaimed property 

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2017 Fall Reporting Checklist Part 2 (Idaho – Minnesota)

Posted By Tim Dressen, UPPO, Thursday, August 17, 2017
Updated: Tuesday, August 22, 2017

Fall reporting season is again upon us. Most U.S. states require holders to file reports by either Oct. 31 or Nov. 1. Following are reporting deadlines for these states, along with helpful links. We have also included information submitted to UPPO by unclaimed property administrators in response to a recent survey requesting updated reporting information. This list is not exclusive to a specific holder industry, so please check the states’ websites for information on industry-specific reporting information and deadlines. 

 

Part 1 covers Alabama through Hawaii.

Part 2 covers Idaho through Minnesota.

Part 3 covers Mississippi through Rhode Island.

Part 4 will cover South Carolina through Wyoming.

 

 

Idaho

Report due: Nov. 1, 2017

Extensions: Extensions may be requested before the report due date. 

 

Contact: UCPBusinessQuestions@sto.idaho.gov or (208) 332-2942 or (877) 388-2942

Idaho holder resources 

 

Illinois 

Report due: Nov. 1, 2017, for all banking and financial organizations, insurance companies (other than life insurance) and governmental entities

Extensions: Extensions may be requested.

 

Contact: Email form, (217) 785-6998

Illinois holder resources

 

Indiana

Report due: Nov. 1, 2017

Extensions: Extensions may be requested at least 30 days before the reporting due date.

 

Contact: Email form, (800) 447-5598

Indiana holder resources

 

Iowa

Report due: Nov. 1, 2017

Extensions: Extensions may be requested at least 30 days before the reporting due date.

 

Contact: upreport@iowa.gov or (515) 281-7546 

Iowa holder resources

 

Notes from UPPO’s state administrator survey:

  • We have a new holder reporting portal that is mandatory for holders to use. There is a link from our website to get to it.
  • Report file type change: Must be electronic in the NAUPA II format. No longer accept paper reporting. 
  • EFT payment due at time of online filing.

 

Kansas

Report due: Nov. 1, 2017

Extensions: Extensions may be requested.

 

Contact: KSHolder@treasurer.ks.gov or (785) 291-3173 

Kansas holder resources

 

Kentucky

Report due: Nov. 1, 2017

Extensions: Extensions may be requested.

 

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

Kentucky holder resources

 

Notes from UPPO’s state administrator survey:

  • Instruction manual/handbook has been updated in the past three months.
  • Kentucky is not requiring Negative Reporting this year.

 

Louisiana

Report due: Oct. 31, 2017

Extensions: Extensions may be requested before the report due date.

 

Contact: (888) 925-4127

Louisiana holder resources

 

Notes from UPPO’s state administrator survey:

  • Louisiana no longer accepts HDE files. Also, Louisiana no longer corrects incomplete data or incorrect codes in a holder's NAUPA files. NAUPA files with errors will be rejected and must be corrected by the holder.
  • Mailing address has not changed, physical address (for overnight delivery) changed prior to last report cycle, but just to be sure, physical address is: 1051 N 3rd St. Room 150, Baton Rouge LA 70802

 

Maine

Report due: Nov. 1, 2017

Extensions: Extensions may be requested before the report due date.

 

Contact: up.holderinquiry@maine.gov or (207) 624-7470

Maine holder resources

 

Maryland

Report due: Oct. 31, 2017

Extensions: Extensions may be requested by mail or email before the report due date.

 

Contact: upholder@comp.state.md.us or (410) 767-1700

Maryland holder resources

 

Notes from UPPO’s state administrator survey:

  • We now have a Holder Handbook that spells out a lot of information.
  • Electronic upload or hand key holder reports direct on state web portal. 
  • Include payments on one check. Not separate check for aggregate and one for over aggregate. Should always send in confirmation of report upload with payment info. 
  • Always use our web portal and send confirmation of payment instructions. 

 

Massachusetts

Report due: Nov. 1, 2017

Extensions: Extensions may be requested by email on company letterhead before the report due date. Include the company FEIN number and reason for extension request.

 

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

Massachusetts holder resources

 

Notes from UPPO’s state administrator survey:

  • New Holder Reporting section and ability to upload NAUPA II formatted file.
  • Report file type change: NAUPA II standard required
  • Holders wishing to use EFT must complete EFT Authorization agreement and email to reporting department. 
  • EFT payment due at time of online filing.

 

Minnesota

Report due: Nov. 1, 2017

Extensions: Extensions may be requested at least 30 days before the reporting due date. 

 

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

Minnesota holder resources

 

Notes from UPPO’s state administrator survey:

  • Paper forms are no longer acceptable. Reporting must be done via electronic file.

 

For detailed information about reporting deadlines, dormancy periods, due diligence requirements, exemptions and deductions, electronic filing and much more, UPPO members can refer to the Jurisdiction Resource Guide

 

Tags:  fall reporting  unclaimed property 

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2017 Fall Reporting Checklist Part 1 (Alabama – Hawaii)

Posted By Tim Dressen, UPPO, Tuesday, August 15, 2017
Updated: Tuesday, August 22, 2017

Fall reporting season is again upon us. Most U.S. states require holders to file reports by either Oct. 31 or Nov. 1. Following are reporting deadlines for these states, along with helpful links. We have also included information submitted to UPPO by unclaimed property administrators in response to a recent survey requesting updated reporting information. This list is not exclusive to a specific holder industry, so please check the states’ websites for information on industry-specific reporting information and deadlines. 

 

Part 1 covers Alabama through Hawaii.

Part 2 covers Idaho through Minnesota

Part 3 will cover Mississippi through Rhode Island.

Part 4 will cover South Carolina through Wyoming.

 

Alabama

Report due: Nov. 1, 2017

Extensions: Extensions may be requested.

 

Contact: Chad Wright: unclaimed@treasury.alabama.gov or (334) 353-3627 or (888) 844-8400

Alabama holder resources 

 

Alaska

Report due: Nov. 1, 2017

Extensions: Extensions may be requested by mail or fax. Include reason for extension request and length of extension needed.

 

Contact: ucproperty@alaska.gov or (907) 465-3726

Alaska holder resources 

 

Arizona

Report due: Nov. 1, 2017

Extensions: Extensions may be requested by fax or email. Include company name, holder number or company FEIN, reason for extension request and length of extension needed. 

 

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

Arizona holder resources 

 

Arkansas

Report due: Nov. 1, 2017

Extensions: Extensions may be requested.

 

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

Arkansas holder resources 

 

Notes from UPPO’s state administrator survey:

  • Instruction manual/handbook has been updated in the past three months.
  • Due diligence threshold change: Act 622 amended periods for providing notice. The effective date of the Act is 8/1/2017. As such, holders will be expected to comply on 2018 filings.
  • Notice timing change: Act 622 amended periods for providing notice. The effective date of the Act is 8/1/2017. As such, holders will be expected to comply on 2018 filings.
  • Report file type change: Arkansas requires all holder reports to be submitted electronically in a NAUPA-formatted file using certain options. Please refer to reporting booklet.
  • New timing requirements: Dormancy period for shares of stock, mutual fund shares, and other security shares has been changed to seven years effective 8/1/2017. Holders will be expected to comply on their 2018 filings.
  • Some common areas of concern have been when holders submit a report without a payment or incorrect payment or when holders submit a payment without a report. We hope that by limiting the methods of reporting, holders may be able to more accurately reconcile their filings.

 

California 

Report due: Oct. 31 for Holder Notice Reports

Extensions: Extensions may be requested no later than 30 days before the due date. 

 

Contact: updholderoutreach@sco.ca.gov or (916) 464-6284 

California holder resources

 

Colorado

Report due: Nov. 1, 2017

Extensions: Extensions may be requested before the due date. Include company name, reason for extension request and length of extension needed. 

 

Contact: GreatCOPayback@state.co.us or (303) 866-6070 or (800) 825-2111

Colorado holder resources 

 

Notes from UPPO’s state administrator survey:

  • You don’t need to mail in disks anymore. Colorado allows businesses to file their unclaimed property reports directly to us through our online portal.
  • Report file type change: Colorado no longer accepts reports with HDE encryption. Your NAUPA file may be in .txt, .hrs or .rpt format. 
  • Colorado does not accept paper reports.

 

District of Columbia

Report due: Nov. 1, 2017

Extensions: Extensions may be requested before the due date. Include reason for extension request. 

 

Contact: DCUnclaimed.Property@dc.gov or (202) 442-8181

District of Columbia holder resources 

 

Notes from UPPO’s state administrator survey:

  • Report file type change: Must be NAUPA format and submitted either electronically or CD

 

Georgia

Report due: Nov. 1, 2017

Extensions: Extensions may be requested by mail or fax at least 30 days before the due date. Include reason for extension request and length of extension needed.

 

Contact: ucpmail@dor.ga.gov or (855) 329-9863

Georgia holder resources 

 

Hawaii

Report due: Nov. 1, 2017

Extensions: Extensions may be requested by mail on company letterhead. Approvals will extend the reporting deadline until Jan. 1. 

 

Contact: (808) 586-1589

Hawaii holder resources 

 

For detailed information about reporting deadlines, dormancy periods, due diligence requirements, exemptions and deductions, electronic filing and much more, UPPO members can refer to the Jurisdiction Resource Guide

 

Tags:  fall reporting  unclaimed property 

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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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UPPO Asks: How do you raise the profile of unclaimed property compliance in your company?

Posted By Administration, Thursday, August 3, 2017

Periodically, UPPO asks members to respond to a question, sharing their ideas, insights, and experience. The recurring UPPO Asks feature is a compilation of their responses. 

 

We recently asked several members: How do you raise the profile of unclaimed property compliance in your company?

 

“I met with leaders and staff in departments that produce unclaimed property items. I explained the importance of keeping good records and following up on unresolved items as soon as possible. Through these meetings, we identified areas for improvement and implemented process changes to reduce the number of items from becoming unclaimed property. I ask other groups to include me when establishing new programs and processes to make sure potential unclaimed property issues are addressed and become part of the new plan. The high rate of retirements is causing a higher than normal turnover in staff. As a result, I set up short meetings with new leaders in departments that produce unclaimed property to make sure they understand the process. I also contact the leader when I hear of something in the works that may affect unclaimed property to make sure I am included from that point forward. I do my best to be proactive, and that takes good communication.”—Jeannie Matthews, unclaimed property administrator, Idaho Power Company

 

 

“We have monthly meetings with our corporate director of finance to review internal processes and to discuss state regulatory updates. Our director of finance also holds meetings with our controllers to review UCP processes and ensure compliance. Our audit team sends an annual compliance questionnaire that requires our business areas to provide proof of UCP compliance and their sign-off. In the past, we sent out quarterly newsletters to provide UCP updates and processes.”—anonymous

 

 

“Our most effective approach to raising the profile of UP compliance is to raise the profile of the entire area of unclaimed property. Early on, we enlisted a ‘sponsor’ (actually the vp of tax) to assist us with projects to initiate compliance. This has evolved into a steering committee (essentially C level executives), which can help us remove obstacles and handle escalations as needed.

 

“Beyond the power of the C-suite, communication and education are key. I tap into every internal newsletter with articles—since there is always a need for content. I arrange training sessions and webinars for a variety of audiences—from educating the steering committee on new requirements to training operational groups on to how to better meet the requirements for compliance. It is impossible to overeducate/overcommunicate! We talk about audit potential and audit defense to be built into our processes. Working in a company where ethics and compliance are both deep in the culture helps to validate our efforts.

 

“We are actively embedding processes to move potential escheatable items into a pre-escheat account and out of the hands of the operational groups. This greatly reduces the complexity of compliance (at least for the supporting teams) and gives the UP team greater visibility and control.

 

“I think the final piece of raising visibility is the same networking that helps in every area of business. There is nothing that can replace having relationships with solid contacts. These folks become ambassadors within their own organizations. My contacts range from internal audit to controllers to AP/AR analysts, and everyone in-between. It becomes much easier to get results when people know you!”—Charlotte S. Kirk, manager, unclaimed property, ABB Inc.

 

 

“Raising the profile of unclaimed property is always a challenge. Audit notices and the need to file a VDA definitely gets attention, though not in a preferred manner. I find that quantifying the potential exposure of accounting methods and procedures is the best means of focusing user groups on the UCP process. It all boils down to dollars and cents, and persistence.”—Pam Runkel, CPA, indirect tax manager, ADT LLC

 

 

“I’ve worked at several (11) different companies over the last 30 years, and have been involved in unclaimed property for 20+ of those years. I’ve started the process in two companies, and enhanced the process in three companies. One company didn’t want anything to do with UCP at all.

 

“I think the best way to get the message across of the importance of UCP compliance is to have an ally in your department that has access to the C-suite. But to get that audience, you must have supporting documentation to show the potential audit exposure, which is a moving target at best. If you can show that this compliance is a value-added proposition, i.e. refunds from the states, limiting audit exposure, then this will help as well.

 

"This is only the beginning of the journey. Once you get the C-suite buy in, then you must get the other players on board to help with gathering the documents, payroll, A/P, A/R, benefits, accounting, etc.”—Mike Marion, CMI, senior manager indirect tax, Fruit of the Loom Inc.

 

 

Now it’s your turn. What do you think are the most important personality traits for an unclaimed property professional? Add a comment to this post to share your response.

 

 

Tags:  Compliance  unclaimed property  UPPO Asks 

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