The introduction of the 2016 Revised Uniform Unclaimed Property Act (RUUPA) by the Uniform Law Commission has prompted state legislatures to review their often antiquated unclaimed property laws, and in many cases introduce legislation to amend or wholly revise these laws. In addition to RUUPA, state legislators may now also refer to the American Bar […]
On June 11, 2019, the California Attorney General filed a Complaint in the Superior Court of California, County of San Francisco (CGC-19-576620), alleging that ClubCorp violated California’s False Claims Act (CFCA) and the California Unclaimed Property and Unfair Competition laws when it knowingly omitted in its unclaimed property reports approximately $10 million in unclaimed initiation […]
Delaware is sending voluntary disclosure agreement invitations to holders believed to be out of compliance with its unclaimed property laws. In a slight change in policy, Delaware indicated that any holders that choose not to enroll in the VDA program will be audited.
The 2019 Advisory Council on Employee Welfare and Pension Benefit Plans, which supports and advises the Department of Labor’s (DOL) Employee Benefits Security Administration (EBSA), will soon be reviewing the procedures used by the states to determine whether the voluntary transfer of uncashed distribution checks to the states’ unclaimed property funds is advancing the DOL’s […]
Recently, Keane noticed an uptick in unclaimed property audits initiated by the state of Massachusetts. We wanted to bring this to the attention of holders incorporated in Massachusetts, as well as those with a physical presence in the state, so that proactive measures can be considered. Proactive measures would include conducting an internal risk assessment […]