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UP Compliance in a COVID-19 Environment

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

The last thing people need to worry about now is how to maneuver the already complex requirements of unclaimed property compliance with the added concerns brought about by COVID-19.

That’s why the Team at True Partners Consulting LLC has created a “just the facts” summary of relevant information below that we hope will be helpful as you try to determine the impact of COVID-19 to filing deadlines or extension requests.  The summary below provides general updates on unclaimed property reporting requirements as of the date of the post.

Upcoming Filing Deadlines Now Through May 2020

All Companies

  • March 30th due date: CT
  • April 15th due date: PA
  • April 30th due date: FL, IL – except banks
  • May 1st Due Date: VT

Life Insurance Only

  • April 30th due dates: AZ, AR CA Notice, DC, MD, NV, NJ OK, VA, VI, WV
  • May 1st due dates: CO, GA, IN, KS, KY, ME, MA, MO, MT, NE, NH, NM, NC, ND, OH, SD, VA

Insurance Companies

  • April 30th due date: MD, NV
  • May 1st due dates: GA, KY, NH, VA

Filing Extension Requests Information as of March 26, 2020. (This information is subject to change.)

  • COVID Extensions Offered
    • CA:  Final filing date for life Insurance corporations to submit Holder Notice Reports is postponed from April 30, 2020 to June 30, 2020.
    • CO: Extension requests may be emailed to Holders@state.co.us .
    • DC: Requests for extensions should be emailed to property@dc.gov.
    • IL: A 30-day extension will be granted for all reports due by April 30, 2020. Requests must be submitted by e-mail to up_report@illinoistreasurer.gov BEFORE close of business day April 9, 2020.  Interest and penalty will be waived for up to 60 days after the end of the IL emergency declaration.
    • MA: Granting a 2-month extension to file for life insurance companies. Questions? Call (617) 367-9333 x 462
    • MD: Moves 4/30 due date for insurance companies to 7/31
    • MO: Granting 30 up to 90 days extension if requested in writing to: UCP@treasurer.mo.gov.
    • NC: Has extended May 1st due date for life insurance companies to June 1, 2020.
    • NJ: Extends April 30th due date to May 31 for life insurance
    • NV: Filing date for insurance companies is extended until June 1, 2020.
    • OK: May submit new form #496 that does not require notarization. You will need to pull new form from State website. Go to: https://www.ok.gov/treasurer/Unclaimed_Property/Holder_Information/ Scroll down to “Holder Report Forms and Instructions and select “Temporary Verification & Checklist NOT Requiring Notary.  Unfortunately, there is no information regarding extensions.  See contact information below under “No Official Guidance Provided.”
    • PA: Extends the April 15th due date for any holder sending a request to report@patreasury.gov
    • VT: Granting 30 day extensions to all holders requesting in writing to: UPCompliance@vermont.gov
  • No Official Guidance Provided
    • AR: The State website does not post an extension request form and it is not clear whether extensions will be granted. If you wish to request an extension, you may try contacting the Compliance Division by e-mail or phone: Josh.Wood@auditor.ar.gov, (501) 371-2103 OR  James.Wooten@auditor.ar.gov, (501) 371-2113
    • MT: The State website does not post an extension request form and it is not clear whether extensions will be granted. If you wish to contact the State, you may try e-mailing your request to:  unclaimedproperty@mt.gov
    • OK: The State website does not post an extension request form and it is not clear whether extensions will be granted. If you wish to request an extension, you may try contacting the State at: Phone Number: (405) 521-4273, Fax Number: (405) 522-6777, e-mail:  holderinfo@treasurer.ok.gov
    • VI: Contact phone (340) 774-7166, fax (340) 774-9458

Risk Factors

  • States may be more lenient on late filings due to COVID-19 but there are no guarantees
  • There are a number of states with upcoming due dates that are silent on whether they will allow extensions. If you wish to contact the State regarding extensions, please see the contact information provided in the above “No Official Guidance Provided” section.
  • Remittances: Many states now accept ACH remittances but some still require check payments. Please check individual websites or contact states directly. If you are unable to get adequate information, you can contact the True Partners Compliance Team.

Please reach out to any member of the True Partners Unclaimed Property Management Team if you have any questions about this or any other developments likely to impact your company.

True Partners will continue to monitor jurisdictional updates and intends to release further True Alerts as additional information becomes available.  True Partners Consulting LLC assumes no responsibility for updating this summary with any future changes made by any jurisdiction(s).  As information may change rapidly in the current environment, relevant jurisdictional statutes and websites should be reviewed at the time of reporting to determine the current and relevant application of information and requirements to your company’s specific facts.