Entering into a Voluntary Disclosure Agreement (VDA) allows holders to come forward with past due properties in order to come into compliance with a state’s unclaimed property law, but with a waiver of interest or, in some states, incurring a reduced interest assessment.
Many states offer ongoing VDA programs for unclaimed property compliance. However, in some states, the program is only offered for a specific time period. The state of Wisconsin has just announced a limited unclaimed property voluntary disclosure program that will be available to holders from February 1, 2022 through February 28, 2023. Holders can utilize the voluntary disclosure program to report and deliver past due property and will receive a waiver of interest and penalties. As with most VDA programs, there are specific eligibility requirements. Indeed, Wisconsin’s VDA program is not available for holders that have been audited by the state since 7/1/2016 or those currently under audit.
Holders entering Wisconsin’s VDA program are required to do the following:
- Fill out the Voluntary Disclosure Agreement Application which is found online.
- Report and deliver all unclaimed property from the previous 5 years .
- Send Due diligence letters within 30 days after acceptance into the program.
-The State has instructed Sovos that it would be acceptable to send due diligence in advance of enrolling/acceptance into the program so long as it falls within the 60-120 day statutory time period found in Wisconsin’s law. - Submit a final report 120 days after acceptance.
- Continue to submit reports for four years following completion of the program.
For additional information or to learn more about Wisconsin’s VDA program go here. By entering into a VDA, businesses can recognize their state unclaimed property exposure and willingly pay any outstanding liabilities and potentially reduce the risk of an audit.
