Unclaimed Property State Compliance Observations From 2020

Ann Fulmer
February 4, 2021

This blog was last updated on September 2, 2021

2020 has been quite the year! As with all aspects of our lives, the unclaimed property world was significantly impacted by this year’s events. We have had to learn to operate our businesses, meet our unclaimed property obligations and effectively function amid office shut downs and virtual workspaces.

The first unclaimed property challenge of 2020 came with the filing of the spring reports. Recognizing the operational difficulties caused by COVID 19, states were very generous in providing filing extensions. While that was a great help in getting the spring reports filed, it delayed the due diligence work efforts needed for the fall reports. Unfortunately, the states assumed that holders were able to reboot their unclaimed property protocols remotely and were not as willing to provide general extensions for fall. This is consistent with the pattern we have been seeing of states becoming increasingly reluctant to approve extensions, except in the case of unexpected circumstances.

As with the private sector, states have adjusted their operations to the “new normal” as demonstrated by a resurgence of new audits being issued, which had been paused due to COVID19. Further, we expect to see an increase in audits to continue into 2021. Third party auditors also picked up where they left off and expect holders to be able to access historical documents, despite continued work from home orders and personnel cuts experienced across most industries. They also like to reference the “extended” period of time that was so graciously given by them to research the populations that they deemed to be potentially escheatable, without taking into consideration the limitations and hardships being experienced by many.

One positive development seen in 2020, is the introduction of enhancements being implemented by States to improve their use of technology to increase efficiency in all aspects of their programs including owner location, claims payments, holder report processing and compliance. 

In the compliance realm, we’re seeing states expand their contracting with third party auditors to assist with voluntary compliance. The early indications are that these new auditor assisted voluntary compliance initiatives resemble a self audit more than they do a traditional VDA. We will keep you updated as we learn more about these new compliance initiatives.

While the struggles related to COVID were many, 2020 saw another state adopt a version of RUUPA (Revised Uniform Unclaimed Property Act). Colorado’s new unclaimed property law went into effect July 1, 2020. Consistent with the other states that have adopted RUUPA, Colorado’s version includes provisions specific to that state which are not included in the uniform act. As with the other RUPPA states, Colorado is bringing its policies and procedures in line with the new law.

Take Action

Learn more about how to manage unclaimed property compliance here

Sign up for Email Updates

Stay up to date with the latest tax and compliance updates that may impact your business.

Author

Ann Fulmer

As National Director of Consulting Services, Ann leads the Sovos Consulting and Advisory Services team that provides clients with a comprehensive approach to achieving and maintaining compliance with state unclaimed property rules and regulations. Ann’s experience as an unclaimed property audit manager for the Commonwealth of Pennsylvania affords her the opportunity to provide the unique insight and knowledge required to represent clients seeking to achieve voluntary compliance, as well as defend those that are facing an unclaimed property audit.
Share this post

North America Unclaimed Property
February 10, 2025
Delaware Announces 2025 VDA Invitation Dates

This blog was last updated on February 10, 2025 Mark your calendars – April 11, 2025 and August 15, 2025 are this year’s anticipated release dates for the Delaware’s Secretary of State (SOS) VDA program invitations. In the event that an organization receives an invitation to participate in the Voluntary Disclosure Agreement (VDA) program  , […]

North America Sales & Use Tax
February 6, 2025
The Tariff and Sales Tax Mishmash – Untying the Mess

This blog was last updated on February 6, 2025 Talk of tariffs dominates the current news cycle with some commentators suggesting that tariffs will spell disaster for our economy while others say the exact opposite. We’ve seen the stock market sometimes fluctuate as tariffs are announced but later suspended, leaving us to wonder whether an […]

retailer dtc wine shipping
North America ShipCompliant
February 6, 2025
Retailer DtC Wine Shipping: The Time Has Come

This blog was last updated on February 6, 2025 By Tom Wark, Executive Director, National Association of Wine Retailers We are often reminded by the media and those in the wine industry—as well as by wine enthusiasts—that the three-tier system of alcohol distribution in most states hinders consumer access to the expansive number of wines […]

Montana 1099-DA
North America Tax Information Reporting
February 5, 2025
State Filing Alert: Montana’s New 1099-DA Requirements for Crypto Brokers

This blog was last updated on February 5, 2025 Reporting digital asset transactions on Form 1099-DA just got a little more complicated. For 2025 transactions, crypto brokers that file Form 1099-DA with the IRS will be required to file the 1099-DA with the State of Montana. This makes Montana the first state to introduce a […]

North America ShipCompliant
January 23, 2025
DtC Wine Shipping in 2024: A Year-in-Review

This blog was last updated on January 28, 2025 The direct-to-consumer (DtC) wine shipping channel faced a storm of challenges in 2024, navigating some of the toughest market conditions in over a decade. As inflation tightened wallets and consumer behaviors shifted, the industry recorded its steepest declines in shipment volume and value since the inception […]