The objective of the unclaimed property due diligence letter is to provide proper notice to the apparent owner of abandoned or unclaimed property in an attempt to resolve the item. This post will analyze the key elements of an effective due diligence mailing to both ensure compliance with state escheat laws and to maximize the return of property to owners.
Unclaimed property compliance for broker dealers and the financial services community can often be an overlooked area of compliance. In addition to Federal regulations such as SEC Rule 17Ad-17, maintaining compliance with 55 unique sets of escheat law is critical to protecting investor accounts and valuable client relationships. In this post, we have outlined 8 pressing unclaimed property concerns facing the brokerage industry.
New York has revised its voluntary compliance program for past-due general ledger property. Eligible holders that enroll can benefit from a reduced reach-back period of 10 years, previously 20 years. Holders electing not to participate in the program are required to use the audit reach-back start date of January 1, 1992.
Keane will be hosting a complimentary seminar in Seattle on May 18th to detail Washington unclaimed property and escheat law and upcoming changes. Highlights will include information on the new Penalty & Interest Waiver program being offered in advance of the fall reporting deadlines.
On March 14, 2017, Michigan 3791 2015 was adopted and sets forth new unclaimed property audit standards under Michigan’s Uniform Unclaimed Property Act. State and third-party auditors contracted by Michigan must now adhere to this new set of standards & practices when conducting an audit.