This blog was last updated on September 15, 2021

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 (DE VDA) process. The underlying goal is to use the discoveries made through the testing of accounts associated with the DE VDA to come into compliance with other states. Organizations electing to participate in the FL CASA receive a waiver on interest and penalties. The scope of the FL CASA is consistent with the DE VDA review period, which covers 10 years plus dormancy and due diligence. It’s important to note that this opportunity is not limited to DE VDA projects administered by FDBR and can be extended to projects administered by TL2Q. To be considered eligible for participation, organizations cannot already be under audit.

Compliance Across Four States: ND, MO, FL, DE

To date, Florida, Missouri and North Dakota provide organizations with the opportunity to piggyback off the DE VDA. Since most of the work needed to identify properties due to FL, MO and ND will already be completed, the expectation is that the CASA’s will be completed in less than a year. If your organization is currently going through the DE VDA program or recently completed the process, the FL, MO and ND CASA programs may provide an excellent opportunity to come into compliance in an efficient manner across multiple states.