Corporate Close-Up: As Unclaimed Property Report Due Dates Creep Closer, California and Other States Issue Guidance to Make Filing Less Frightening


For most people, the end of October means Halloween is quickly approaching. For unclaimed property holders, it serves as a reminder that a different, but sometimes equally scary, date is approaching – the due date for filing annual unclaimed property reports.

Each year, unclaimed property holders are required to file an annual report identifying property that has been unclaimed for the required dormancy period and to remit the property to the state. In the majority of states, this annual report is due November 1st  for all unclaimed property holders other than life insurance companies.

 As the filing date creeps closer, several states have published new or revised guidance for property holders. In the last month, Kentucky and Connecticut both updated the instructions for their 2014 holder reports, Wisconsin revised its Unclaimed Property Holder Report Guide, Montana issued a press release reminding taxpayers about the upcoming deadline and California published its Fall 2014 Unclaimed Property Program newsletter highlighting important news and useful information in order assist holders with their California reporting requirements.

The California newsletter reminds unclaimed property holders that the annual holder notice report should include a complete listing of currently reportable unclaimed property but should not include the remittance of the properties. It also suggests that holders verify the following items in order to ensure their report is approved and to avoid potential interest assessments:

  • the complete contact information is provided for the person in the company responsible for completing the report (the “Holder Contact Information”);
  • the complete contact information is provided for the person in the company responsible for handling inquiries from property owners (the “Property Owner Contact Information”);
  • a valid Committee on Uniform Securities Identification Procedures (CUSIP) number is included for each security reported; and
  • an original signature, not a photocopy or a stamp in lieu of a signature, is on the report.

 According to the newsletter, reports missing the holder contact information, a valid CUSIP number or an original signature will be rejected. If the property owner contact information is missing, the report will not be rejected and the holder contact information will be printed on due diligent notices sent to the property owners instead.

California’s newsletter also includes a detailed discussion of when and how interest relating to the holder notice report is assessed. As part of this discussion, it highlights the frightening fact that interest may be assessed against delinquent property on the holder notice report even if the property was returned to the rightful owner after the holder notice report was submitted and before the holder remit report and remittances are timely submitted to the California State Controller's office.

Unclaimed property holders in a minority of states can sleep easy on October 31st, knowing they have at least a little bit of extra time before their annual report is due. A listing of these states, other than New York, and their filing deadlines can be found in the chart below. New York unclaimed property reports are due October 10 for utilities, November 10 for banks and June 1 for travelers checks and money orders.

State

Annual Unclaimed Property Report
Due Date

Connecticut March 31
Delaware March 1
Florida May 1
Michigan July 1
Pennsylvania April 15
Tennessee May 1
Texas July 1
Vermont May 1

 

By Lauren E. Colandreo

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