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Unclaimed Property and Cryptocurrency:  State Reporting Considerations 

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 […]

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Reciprocity in Unclaimed Property

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 […]

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Recent Developments Impacting the Delaware Unclaimed Property VDA

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 […]

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Delaware Unclaimed Property Law Changes: DE S 103 & DE S 104

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 […]

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Florida Contractor Assisted Self-Audit Program (CASA)

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 […]

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Alaska Unclaimed Property Notices

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 […]

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Securities Unclaimed Property

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 […]

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Unclaimed Property and Cryptocurrency: Due Diligence Requirements and Compliance

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 […]

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Unclaimed Property Pre-Presumption and Electronic Outreach

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 […]

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Delaware Unclaimed Property VDA Notices

Delaware VDA Invitation Reminders Sent Out June 14, 2021 Pursuant to 12 Del. C. §1173(b), the Delaware Secretary of State (SOS) distributed a new wave of letters inviting companies to enter the Voluntary Disclosure Agreement (VDA) Program. The Delaware Office of Unclaimed Property sent reminder letters the week of June 14, 2021 to holders that […]

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Maryland Unclaimed Property Audit Notices

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 […]

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General Ledger Unclaimed Property

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 […]

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Anatomy of a Due Diligence Letter

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 […]

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Unclaimed Property Reporting for Retail Businesses

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 […]

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New York Unclaimed Property Self-Directed Compliance Program

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 […]

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The Latest RUUPA Updates

On July 13, 2016 the Uniform Law Commission (ULC) approved its drafting committee’s final draft of the Revised Uniform Unclaimed Property Act (RUUPA). The approved RUUPA is now considered the latest version of a model law that will serve as reference for state legislatures in modifying and enhancing current state unclaimed property statutes. The introduction […]

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Healthcare Industry Insights into Unclaimed Property

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 […]

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When Are Unclaimed Property Reports Due and Other FAQs

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 […]

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