A Look Back at Fall Unclaimed Property Reporting

Joseph Pollock
December 4, 2023

Another October unclaimed property filing season is now over for both clients and Sovos. Overall, 70% of reports filed by Sovos on behalf of our clients occur for states with deadlines on October 31 and November 1. The last 60 days of the filing period require significant coordination between our clients and Sovos. Many tasks, including due diligence letter processing, reconciliation, report generation and delivery to the state, are performed within a condensed time period. Generally, the last 60 days won’t pass without a few adjustments, and this filing period was no exception.

What were some unclaimed property reporting challenges?

One of the more challenging October detours focused on holder numbers required to file electronic NAUPA II reports on Maryland’s state website. There were delays in obtaining the holder number from the state. Specifically, first-time filers encountered issues obtaining the number necessary for submission. As a result, Maryland granted a reprieve from interest to first-time holders, as long as reports are received by December 31, 2023. This gave Maryland time to address the delays in providing the required holder IDs; facilitate engagement between the state, holders and Sovos; and then allocate time to generate NAUPA II reports and deliver them to the state. This provided sufficient time for all parties to make corrections and file by the revised deadline.

Another adjustment we faced was in Arkansas, which provided clarity on required data points for cashier checks, emphasizing the inclusion of payee and remitter information. Making this adjustment presents a complex challenge as it is specific to each state and not a common practice across others. This feedback mirrors the industry’s experience with Illinois a few years ago. Going forward, adjustments will need to be made to accommodate the request.  Many financial institutions operate within a regional footprint, and they may not have encountered a similar situation with Illinois.

Specific to Sovos, earlier in the filing season, Georgia requested that our clients begin filing NAUPA reports directly on the Georgia state website instead of filing directly via Sovos software. This is a straightforward process for our applications, and they do not necessitate a hotfix.

Due to variations in requirements across states, our applications must be adaptable to changes efficiently and without requiring programming adjustments. Navigating a filing period with changes like these is commonplace. Fortunately, the team adjusted as events unfolded.

How Sovos can help

The collaborative efforts of our dedicated team members ensured a seamless transition for our clients, reinforcing Sovos’ commitment to providing exceptional service amid an extremely intense filing period. We look forward to continually adapting to regulatory and operational changes. The team will undoubtedly be eagerly anticipating a well-deserved break before the upcoming due diligence deadlines. But Puerto Rico filings will require our attention in December!

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Author

Joseph Pollock

Joseph Pollock is Director of Compliance Services. Joe joined Sovos as part of the Keane acquisition in 2020 and has over 17 years of unclaimed property experience. He currently leads the Sovos unclaimed property practice that is responsible for annual unclaimed property filings. Joe is also a member of UPPO and serves as a member of the Member Services Committee.
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