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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 […]

Historically, the healthcare industry has experienced challenges in identifying and reporting unclaimed property. This is due to several reasons including a lack of clear statutory guidance, limited understanding of the potential unclaimed property liabilities which they are truly subject, and conflicting laws (i.e., refund recoupment, prompt payment, HIPAA, etc.).  The fundamental understanding that healthcare entities […]

When are unclaimed property reports due? This is a fairly common question asked by holders that are new to the escheat reporting process, or not as well versed in the intricacies of escheatment reporting. Fortunately, Sovos has provided answers to some of the most frequently asked escheat reporting questions to help your organization survive unclaimed […]

Most unclaimed property professionals are familiar with the story of Verus Analytics, LLC’s (“Verus”)[1] appearance on the contract audit “field of play” some ten years ago, as it cut a swath across the life insurance industry with audits focused on the industry’s failure to report and remit unclaimed life insurance proceeds based on the insurers […]

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 […]

Unclaimed property management can fall under a variety of responsibilities ranging from CFO to accounting—but typically resides within the accounting or financial reporting departments. Every company generates potential unclaimed property through regular business functions such as payroll. With over 80% of companies considered non-compliant with unclaimed property laws and regulations and the number of audits […]

For the past 70 years, unclaimed property reporting requirements have been challenging for US businesses. Understanding the nuances of individual state statutes and how to comply effectively and efficiently has caused many sleepless nights for unclaimed property professionals. Well, that may be a bit extreme, however, state regulations are difficult to master. When the first […]

By: Laurie Andrews, Gary Joseph and Brian McCarthy The unclaimed property audit landscape is forever changing.  Just a few years ago there were only a handful of active third party contingent fee audit firms, whereas today there are currently 8+ audit firms contracted by the states to audit companies to ensure compliance with unclaimed property.  […]

By: Gary Joseph and Paola Narez In order to maintain compliance with states’ unclaimed property statutes, holders must understand the types of unclaimed properties they are susceptible to generating and the conditions that would begin the running of the dormancy period for each property type (the “dormancy trigger”).  Property becomes abandoned or unclaimed when an […]