To help you prepare for the 2018 spring reporting season, we’ve put together a timeline which covers what you should be doing and when to do it.
For more information about the upcoming spring reporting season, watch the on-demand replay of our latest webinar.
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How State Deadlines Affect Reporting Timelines
With unclaimed property reporting, there’s no such thing as uniformity. There are a variety of deadlines from a variety of states, which truly makes unclaimed property compliance a year-round effort.
Spring Unclaimed Property Deadline Highlights
The spring state deadlines range from March 1st to April 30th. Some states, specifically Michigan and Texas, have obligations in July.
Here are the deadlines for states with spring deadlines for General Ledger properties, unless otherwise noted. Many states have specific deadlines for certain property types, such as Life Insurance property.
- Delaware – March 1st except for banks and insurance.
- New York – March 10th except for banks, insurance, and utilities
- Connecticut – March 31st for all properties
- Pennsylvania – April 15th for all properties
- Florida – April 30th for all properties
- Vermont – April 30th for all properties
- Illinois – April 30th for some properties
- Tennessee – April 30th for all properties
Establishing an Unclaimed Property Reporting Timeline
Here at Keane, we’ve established a year-round timeline to help our clients stay in compliance with unclaimed property reporting. Spring reporting really begins in December, then it flows through January into March. In April, you can take a brief break and then ramp up again for fall reporting.
A typical timeline we would use with our clients for spring reporting deadlines is as follows:
- December: We typically start to get data from our clients at the end of the year in order to begin our escheat eligibility analysis process.
- January – February: Prepare and mail state-mandated due diligence mailings, managing return responses and removing those properties from final reports.
- March – July: Prepare and submit final reports
Don’t Forget About Early Mailing States and Due Diligence Considerations
States are very specific regarding the timing of due diligence letters and some mailings take place earlier in the timeline than others, so be on the lookout for those requirements. We refer to the states where due diligence is performed using the analysis completed for the prior cycle as Early Mailing States.
For instance, Pennsylvania requires holders to mail due diligence letters by the beginning of December even though the report is not due until April 15th.
Letters for owners in Connecticut and Delaware need to be out by December 31st. New York actually has two deadlines in December. For utilities, banks, life and non-life insurance carriers, letters must be sent by December 10th. For securities that are dividend reinvestments, letters must be sent by December 31st.
Jurisdictions are also specific about the information in due diligence letters. Learn more about unclaimed property due diligence letters.
What to Do in the Fall to Prepare for Spring Reporting Deadlines
November: For those early mailing states, you should be revisiting your policies and procedures. It is very important to make sure that your policy and procedures are up to date.
Your unclaimed property policy should be a dynamic document that’s updated prior to each cycle to make sure that you have incorporated any changes in your systems, changes in responsibilities and so forth.
You should be identifying and remediating any fall reporting pain points. Consider having a post-mortem after the fall cycle to determine what worked, and what needs to be improved in your organization for the next cycle.
December: You should be looking at your early mailing states and performing your eligibility analysis. Identify anything that is currently due. For anything that’s past due, consider trying to remediate.
Remediation consists of performing some form of special outreach effort to try and reunite the owner with their property or asset. Remediating past-due property before it’s reported to the state could potentially save your company some penalties and interest.
Behind The Timeline? Keane Can Help
Following our recommended timeline can go a long way in helping you prepare for each reporting season. If you are already behind schedule, contact Keane to see how we can help you stay compliant and avoid costly fines, penalties, and unclaimed property audits.