New deadlines for the Delaware voluntary disclosure program have been set forth following the passage of Senate Bill 228, which was signed by Governor Jack Markell on June 30th. The new law is effective immediately and provides holders with an extended opportunity to enroll in and complete Delaware’s Voluntary Disclosure Program being conducted by the Secretary of State.
First and foremost, the new deadline to submit a letter of intent to enter into this voluntary compliance initiative has been extended to September 30, 2014. The completion date for the VDA program has also been extended by one year to July 1, 2016 in order to provide sufficient time for all holders to complete the voluntary disclosure agreement and for the Secretary of State to process all such voluntary self-disclosures agreements. The extension of time to complete the VDA process applies to holders who are currently enrolled in the VDA program as well as those who enter the program by the September 30, 2014 date.
In addition to the deadline changes included within DE SB 228, a condition of confidentiality was implemented that will require the Department of Finance and Secretary of State to keep all financial information obtained during audits, settlements, or voluntary disclosure agreements confidential. SB 228 also changes the penalties assessed for failure to file a report and eliminates the assessment of interest on outstanding unpaid amounts.
Why Enroll in the Delaware Voluntary Disclosure Program?
Keane’s Unclaimed Property team encourages holders with a reporting obligation to Delaware to take advantage of these extensions and enroll in the Delaware voluntary disclosure program. In an effort to expedite the VDA process and ensure compliance, the leveraging the services of an experienced holder advocate are also encouraged.
To receive complete details regarding SB 228, please login to Keane’s Compliance Portal and refer to the Legislative Alerts section. Details on this bill can also be found within the Legislative Tracking areas for subscribers of the Compliance Resource Package.