Unclaimed Property Enforcement Landscape

Enforcement

Among the multiple state-mandated responsibilities companies (“holders”) must adhere to, one category that is often overlooked is unclaimed property. All 50 states have unclaimed property laws and holders are required to submit unclaimed property reports to states annually.

Reporting errors, gaps in reporting, and recent acquisitions/mergers may trigger states to pursue enforcement techniques. States deploy several methods to address compliance, including audits, Voluntary Disclosure Agreements (“VDA”), Compliance Reviews, Verified Reports, and Self-Audits.

Holders must proactively develop detailed policies/procedures to avoid enforcement. When developing your compliance framework, consider how the changing legislature, dormancy periods, due diligence requirements, and reporting deadlines impact your business. Contact us if you need guidance in enhancing your compliance framework or have received communication from a state.