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Delaware changed its custodian for the reporting of securities to Wells Fargo Advisors. Any holders reporting and remitting securities to Delaware should follow the updated instructions that are available in the Holder Reporting Guide (page 40) ( https://unclaimedproperty.delaware.gov/docs/DE_Holder_Manual_2024.pdf) . Delaware provided the following reminders: Five days prior to delivery of securities, holders must e-mail their intent to deliver to Delaware’s custodian via an Excel Document containing the issue name, CUSIP, ticker symbol, number of shares, and the delivering party’s DTC participant number and/or delivering party’s information. Please email the Excel list to  Delawarecustody@kelmarassoc.com and escheat.holderquestions@delaware.gov . All reported shares should be delivered via ACATS using the following instructions: Wells Fargo Clearing Services, LLC ACATS Particip ant # 0141 Reference: State of Delaware Main Account Account # 3294-9051     Worthless or Non-transferable securities should not be reported until the securities become transferable or have gained value. Non-transferable securities with value should be liquidated by the holder, and then reported and remitted as the cash proceeds. Advisely offers unclaimed property management and reporting services for organizations during the annual reporting cycle. Contact Eric Burke ( eburke@adviselyllc.com ) to discuss the Advisely reporting checklist.

The State of Delaware recently issued another batch of verified report notices to several companies (“holders”). Holders are required to respond to the notice within 30 days. The goal of the verified report is to validate that the holder’s most recent annual report is complete and accurate. The process is often conducted by a third-party audit firm. The state requests the holder to verify the previous report, provide a list of entities included within that report, and submit a copy of unclaimed property policies and procedures (if applicable). Failure to adequately respond to the requests may result in additional enforcement efforts (Compliance Review, Voluntary Disclosure Agreement program, or examination). We encourage holders to review current policies and procedures to confirm they align with state expectations. If you have received correspondence from the state or need additional information about the process, contact Eric Burke ( eburke@adviselyllc.com ).

Those tasked with unclaimed property compliance duties in their organization understand that the reporting process is a year-round responsibility. As unclaimed property impacts several departments in a particular business, companies should implement procedural enhancements to prepare for reporting deadlines. Many jurisdictions have different requirements and reporting deadlines. Each department should work cohesively to address property (such as aged credits or uncashed disbursements) before reaching dormancy. Many states have unclaimed property reporting deadlines in the fall. Advisely recommends that companies compile listings of property reaching dormancy and begin owner outreach at least 4-6 months before the reporting deadline. As this timeframe aligns with many of the statutorily required due diligence mailings mandated by the states, it ensures owners have the best likelihood of receiving their unclaimed funds prior to being reported to the state. The time is now – identify aged property and work with your organization to reunite owners with their funds. At Advisely, we partner with companies using our technology and experience to proactively activate owner outreach and due diligence. Our process helps companies maintain relationships with customers, vendors, employees, and shareholders. Implementing tracking systems and organizing accurate owner contact information can be a daunting task if not addressed appropriately. Our professionals leverage our resources to help companies stay in compliance and avoid penalties and other state enforcement. For additional information regarding our services, contact Eric Burke ( eburke@adviselyllc.com ).

In Advisely’s March 7, 2024 blog post, we discussed the Delaware Voluntary Disclosure Agreement (“VDA”) program for unclaimed property. Delaware issues “invitations” to companies to enroll in the VDA program. The most recent mailings were issued in late February. The communication explains that failure to respond within 90 days will likely result in an audit. As the deadline is quickly approaching, companies should ensure personnel are educated regarding the current internal policies and how the VDA response will impact your organization. There is no one-size-fits-all approach to unclaimed property enforcement. As our experts have extensive experience with the VDA and audit processes, contact us to guide you through your options.