Blog

If you are currently enrolled in Delaware’s voluntary disclosure agreement (VDA) program, it is very important to provide periodic updates to the VDA administrator contact assigned to you – either Faegre Drinker Biddle & Reath LLP or TL2Q, LLC.. All correspondence from the state or it’s administrators should be treated seriously and responded to in […]

As offices around the world begin to reopen after nearly 18 months of employees working from home, many buildings aren’t as full as they used to be. In fact, 2.7% of the workforce quit their jobs in June 2021 alone. This is caused in large part by what many are calling the “Great Resignation.” Finance […]

The State of Delaware Department of Finance sent out letters to Holders requesting verification of annual unclaimed property reports for property presumed abandoned as of December 31,  2020. These Delaware reporting verification letters are targeted to holders that previously reported unclaimed property to Delaware but did not submit a 2020 report, which was due on […]

So, who wants to read another article about unclaimed property audits and how burdensome they are?  I mean sure, most of you have either heard, read about, or experienced firsthand how difficult the examinations are to navigate and how long they can be, but rarely do we hear any good news when it comes to […]

In my previous two unclaimed property and cryptocurrency blogs posts titled, “Regulation and the Impact on Digital Assets” and “Due Diligence Requirements and Compliance,” we explored the impact of unclaimed property regulations in the virtual currency world and the what, why, when and how of due diligence compliance.     Now that you have completed your due […]

Reciprocity in unclaimed property: why refrain from the practice of reciprocity when it seems so simple? Reciprocity or reciprocal filing came about in 1954 to keep holders from duplicate reporting liability. In other words, if a holder reported unclaimed property to one state (state A for example) and another state (state B) had a better […]

60-Day Response Period Extended for February VDA Recipients The deadline to respond to Delaware unclaimed property VDA invitations mailed in February 2021 was extended to July 31, 2021. Per an announcement posted to the DE Secretary of State’s website, reminder letters were sent the week of June 14, 2021 to holders that received, but have […]

With over 1.5 million entities incorporated in Delaware and only 20% of companies in compliance with unclaimed property laws, any legislative changes Delaware makes causes a stir in the industry. Delaware recently passed two bills with significant impact on unclaimed property in the state, DE S 103 and DE S 104. Our dedicated unclaimed property […]

Put your Delaware Voluntary Disclosure Agreement (DE VDA) to Work with Florida CASA The Florida Department of Financial Services recently announced its participation in the Faegre Drinker, Biddle & Reath LLP (FDBR) Contractor Assisted Self-Audit Program (CASA) that seeks to increase the utilization of the work efforts organizations invest in the Delaware Voluntary Disclosure Agreement […]

The Alaska Department of Revenue is sending out notices alerting holders of their obligations to file unclaimed property reports to the state in accordance with Alaska’s Uniform Unclaimed Property Act. These communications are targeted to those that filed unclaimed property reports and remitted property to Alaska in 2019 but did not in 2020. Due to […]

The securities industry continues to be an area of focus from an unclaimed property standpoint. Individual issuers and transfer agents are being targeted for audits.  The auditors are using traditional techniques to confirm that holders are in compliance with unclaimed property laws but they are also using nontraditional techniques to identify audit populations and shifting […]

In my previous blog, Unclaimed Property and Cryptocurrency: Regulation and the Impact on Digital Assets, we explored the impact of unclaimed property regulations in the virtual currency world. We determined that if you have a direct legal obligation to the owner, it is important that you review the requirements for unclaimed property reporting and partner […]

There are many things to keep track of with unclaimed property so it’s understandable that certain items, such as unclaimed property pre-presumption outreach and electronic due diligence requirements, can be overlooked. However, they are part of unclaimed property law and therefore require compliance. Sovos tracks all nuances of unclaimed property law and ensures that our […]

It has recently come to our attention that the state of Maryland has increased its audit efforts. Due to the negative economic impact resulting from COVID-19, Sovos’ consulting, reporting and regulatory teams have been preparing for increased unclaimed property compliance enforcement efforts to shore up struggling state budgets. Pursuant to Title 17, Abandoned Property Act […]

General ledger is an area all companies, regardless of industry, should monitor for unclaimed property compliance. In this section, general ledger refers to unclaimed property potentially generated from payroll, accounts payable and accounts receivable credit balances. These accounting cycles or functions are present in every organization, therefore it’s important companies explore and review these areas […]

What is unclaimed property due diligence? An unclaimed property due diligence letter is an organization’s last chance at contacting an apparent owner and preventing their property from escheatment. Each state or reporting jurisdiction has its own unique set of requirements and standards. Due diligence letters are typically required to be sent 30 to 120 days […]

The evaluation of retail unclaimed property compliance can be quite complex when taking into account the nature of the business.  On one hand, the organizational and accounting structure of a retail company presents challenges in the form of determining which state properties should be reported and remitted to, per the priority rulings.  On the other […]

Continuing the trend in 2021, New York unclaimed property recently introduced the NY Self-Directed Compliance Program  geared towards identifying both non-reporters and companies that reported in 2021, but failed to report property types expected to be seen. Due to negative economic impact resulting from COVID-19, Sovos’ consulting, reporting and regulatory teams have been preparing for […]