There has been an interesting development from the Commonwealth of Massachusetts State Treasurer’s Office as they introduce a new wave of unclaimed property self-review invitations. Recipients of these self-review invitations have 30 days from the receipt of the letter to log into the state website to provide updated contact information. This timeline is shorter than other states, such as Delaware, who offer a 60-day response window.
If you receive one of these invitations, Sovos’ Unclaimed Property Consulting Team has extensive experience assisting organizations as a Holder Advocate, ensuring that all requirements of the Massachusetts Self-Review program are completed in an efficient and compliant manner.
Check your Mail: MA Self-Review Invitation Letters April 2021
Encourage your company’s unclaimed property contacts, mail room and upper management to be on the lookout for this letter. Oftentimes, when holders receive these letters they are not brought to the attention of the appropriate person or department causing the company to miss their response window. With many companies still working from home due to COVID-19, it is imperative that this self-review invitation doesn’t go unnoticed.
In other states, such as Delaware, holders that do not respond to the invitation letter within the required time frame are referred to a State Escheator for audit examination. As this is a new process for Massachusetts, it’s still not determined if no response within the 30-day window will result in an audit initiation.
Are you Prepared for a Self-Review or Audit?
- Do you have formal and documented unclaimed property policies and procedures? States require regularly updated unclaimed property policies and procedures. Typically, this is one of the first items requested for a self-review or audit.
- How long are you maintaining copies of your unclaimed property reports and owner records? Each state has its own regulations surrounding how long you must retain reports and records. If your company does not have these reports or records the state may use estimation.
- How do you keep up to date on unclaimed property compliance laws? States change and enact new unclaimed property legislation on a regular basis. If you’re using a software or other tool that requires manual updating, this puts your company at significant risk for non-compliance.
- Do you know if you have any past and current due unclaimed property? Examine your corporate and financial records to identify potential exposure areas for liability and risk.
Massachusetts advises that upon response to the self-review letter, holders may be contacted by a representative from Kelmar Associates, LLC (“Kelmar”), as Massachusetts has contracted with them to assist with the administration of this outreach process. Kelmar is a well-known third-party auditor in unclaimed property.
As states and third-party auditors continue to expand their compliance efforts, there is a growing concern that the self-review initiative is a forerunner to increased audits. Sovos’ experts expect to see an increasing trend in audits due to the budget shortfalls many states are experiencing from the COVID-19 pandemic.
Learn how Sovos Unclaimed Property Consulting solutions can help you meet your compliance needs. Talk to an expert today.