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Preparing for the upcoming Unclaimed Property Fall 2021 Compliance Season

By: Cathleen A. Bucholtz Jim Sadik Steven Swaigenbaum Robert M. Tucci Troy R. Wangen |

Summer is winding down (sad!) and now is the time to prepare for Fall unclaimed property (UP) compliance.  Whether you have just taken on unclaimed property compliance or have been doing it for years, here are five things to keep in mind when getting ready the Fall 2021 unclaimed property compliance season:

  1. Due Diligence. If you haven’t done so yet, the window of time to send your statutorily required due diligence notification letters to the owners of unclaimed property held by your company is quickly closing.  In addition to the strict timing requirements on when the letters must be sent, make sure that your team is following newly adopted legislative requirements impacting the dollar thresholds and content of these letters.
  2. Legislative Changes. While many states held off on passing new legislation last year due to Covid-19, in 2021 states have made up for lost time by enacting new laws impacting unclaimed property.  Make sure that your team understands these changes and how they may impact the Fall 2021 unclaimed property reporting process.
  3. Signing and Notarization. Last year, many states adopted special provision regarding their signing and notarization requirements due to the impact of Covid-19.  Make sure to confirm which of these requirements may have changed again as states move into the Fall 2021 reporting season.
  4. Payment Methods. Confirm what forms of payment are accepted by each jurisdiction, and which states require electronic payments.  If issuing checks, confirm with your internal team how much time is needed to get a check processed.  If making an electronic payment to a state, make sure to reconfirm each state’s banking information as this information can change.
  5. Electronic Reporting. Many jurisdictions now require that reports be submitted electronically, even if the company is remitting the property to the state by check.  Be sure and confirm which states require electronic reporting and that your team knows the proper way to submit, and document, that the correct report has been submitted.

We help hundreds of organizations with their UP compliance reporting needs, and we are available to assist your company with all of its annual UP compliance issues or concerns.  Other UP services include: reviewing and creating policies and procedures, voluntary disclosure programs, audit defense, exposure quantification and analysis, merger and acquisition due diligence, and gift card and stored value card consulting.

If you are interested in learning more about how we can help with any of your UP needs, please reach out to the members of the True Partners Consulting Unclaimed Property Management Team to set up a call.