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 […]
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 […]
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 […]
UPExpress, the free tool for companies to eFile unclaimed property reports directly to participating states, was discontinued at the end of 2020 because the current file formats no longer aligned with many of the state’s newly implemented technologies. You can still eFile unclaimed property reports to states that accept online reporting. However, if you plan […]
Understanding unclaimed property dormancy periods by state and executing the appropriate decisions can make or break your company’s unclaimed property program. This is due primarily to the fact that each state has varying dormancy periods. To complicate matters even further, each state has specific dormancy periods for each corresponding property type. As a result, determining […]
This blog was updated on July 13, 2022 The National Association of Unclaimed Property Administrator’s (NAUPA) III format for unclaimed property has been in the works for a while now, and the first draft was scheduled to be published on July 5, 2022. Upon checking NAUPA’s website on July 5, 2022, the following message was […]
Did your company receive an invitation in February 2020 to join the Delaware Voluntary Disclosure Agreement Program (SOS VDA Program)? If so, you have extra time to enroll in the program. The Office of Unclaimed Property extended the enrollment deadline to July 18, 2020. How to enroll If you intend to enroll, send a completed […]
Unclaimed property compliance is a year-round job. Preparations must be made monthly in order to stay compliant. Below are the top 5 ways you can stay ahead of your unclaimed property obligations, before they turn into penalties. 1. Review procedures and document them: A lack of good audit trails and procedure documentation is commonplace in […]
Healthcare providers build up patient credit balances from collecting more coinsurance, copays, and deductibles than they earn. Unfortunately, because the fees are unearned, the healthcare provider has inadvertently accepted fiduciary responsibility for the funds. In addition to safeguarding the funds from potential loss, the healthcare provider is now facing penalties and interest from the states […]