The unclaimed property filing season is broken down into three major categories: Analysis, Due Diligence and Final Reports. The cut-off date for the “Fall” filing season is June 30, the analysis is typically performed during July and diligence mailings are executed by August 31. Due diligence mailing requirements allow 30 days for a recipient to respond.
Therefore, in mid-September, we have transitioned to the most frenetic stage of the process: Final Reports. Right in time for the end of summer, back to school, the beginning of football season and the home stretch for Major League Baseball. While the effort required to complete final reports happens very quickly compared to analysis, the looming deadline always adds an element of pressure for our clients and managed services team.
Two significant unclaimed property filing components completed thus far
- The Analysis – Identifies current due, past due and future due properties for escheatment. It also details the item that meets the state-mandated due diligence requirement, those that do not because they are below the state-specific threshold, are in a state that has a Return by Post Office (RPO) or in a state with a “bad” address provision.
- Due Diligence – A notification to eligible property holders. The statutory due diligence requirements vary by state, holder and property type. Most states require the written notification mailed by holders to the owner of potential unclaimed property no less than 60 days and no more than 180 days (about six months) prior to the filing deadline. In addition to sending a letter, some states require advertising owners’ names and addresses in one of their local newspapers and/or sending an electronic notification if the owner opted into electronic communication.
If you have completed these milestones, you are in great shape to finish the Fall unclaimed property season strong. Congratulations, you are in the driver’s seat, headed toward success. If you are behind on these milestones, you may have the ability to file extensions. However, the deadline to file extensions is quickly approaching. Several states require extension requests to be filed 30 days prior to a filing deadline. As with all things in unclaimed property, extension requirements and considerations to file an extension vary by state.
One of the final things to watch for in filing season is a last-minute change to the filing requirements. While most dormancy changes enacted by states have long since passed and became effective, the end of September through the beginning of October typically have significant administrative changes by numerous states. The changes range from new brokerage accounts for share delivery to a new state website for National Association of Unclaimed Property Administrators (NAUPA) delivery or NAUPA file encryption. Sovos’ Regulatory team monitors any changes and updates our state profiles accordingly.