The National Association of Unclaimed Property Administrators (NAUPA) has finally published its long-anticipated draft of the proposed NAUPA III file format after a delay of the anticipated July 5, 2022 release. The 62-page draft includes sweeping changes and represents a major update to the current NAUPA II format. According to NAUPA, “the new version has been created to make electronic reporting more uniform.”
The NAUPA Standard Electronic File Format is a standard set of codes that has been widely used to file unclaimed property reports to U.S. states since 1990, with every state having adopted the NAUPA II Format.
As suspected, the proposed NAUPA III has not only added new data elements and property codes but has moved from the fixed width format to Extensible Markup Language (XML). NAUPA believes that XML provides a more flexible architecture for reporting, minimizing mistakes and maximizing accurate reporting. Further, existing property codes have been radically changed. Some have been removed, others expanded, and all are transitioned from four digit to five-digit codes.
NAUPA III will bring greater flexibility to UP owners and holders. For example, there will be a greater chance for UP owners to claim owed property if owners’ non-standard addresses or additional identifying information (e.g., driver’s license information) can be included in the report.
“The existing property codes have been extensively reviewed to create a more uniform, streamlined system,” NAUPA states on its website. “We’re seeking feedback from stakeholders on the proposed property code changes, and to review the descriptions for completeness and clarity.”
There will be a transition period to NAUPA III and “will co-exist with NAUPA II during transition to the new format,” according to NAUPA. Sovos predicts that holders will potentially be able to start utilizing the new format on an optional basis in the fall of 2023. NAUPA has not yet specifically stated when NAUPA III will be mandated, but it could be required by the fall of 2024.
The proposal specifically invites feedback from stakeholders. Comments, thoughts and suggestions can be submitted by February 28, 2023. To do so, interested parties can visit here.
Sovos will continue to monitor for developments.
Still have questions about NAUPA and unclaimed property? Reach out to the Sovos team for more information.