Regulatory Analysis

Introduced April 14, 2021 this bill, if enacted, would become effective on August 1, 2021; with certain provisions applying retroactively to any claims, examinations, or litigation pending as of the effective date. This proposed bill covers three areas: audit practices, Voluntary Disclosure Agreements (VDA’s) and Individual Retirement Accounts (IRA’s). If passed this bill would expand […]

Introduced April 14, 2021 this bill, if enacted, would become effective on August 1, 2021. This bill would add provisions to the Delaware Unclaimed Property Act specifically requiring the reporting and remittance of virtual currency. DE S 103 defines virtual currency as a digital representation of value, including cryptocurrency, that does not have legal tender […]

Enacted and effective by signature of the Governor on April 15, 2021. The bill makes multiple changes to the Revised Uniform Unclaimed Property Act (the “Act”). This bill provides a specific definition of Financial Organization Loyalty Cards and exempts such items from the definition of Property under the Act. CO S 121 also removed two […]

MA Self Review Invitation Letters Update: April 2021 Pursuant to The Massachusetts Unclaimed Property Law (M.G.L.c. 200A), the Commonwealth of Massachusetts, State Treasurer’s Office (the “Commonwealth”) issued a wave of letters inviting companies to participate in their Self-Review Program. The Commonwealth mailed notices to holders believed to be noncompliant with Massachusetts unclaimed property reporting laws and […]

DE VDA Invitation Letters Update: February 19, 2021 Pursuant to 12 Del. C. §1173(b), the Delaware Secretary of State (SOS) has distributed a new wave of letters inviting companies to enter the unclaimed property Voluntary Disclosure Agreement (VDA) Program. Holders have 60 days from the date of the letter to enroll in the SOS VDA […]