The post below, authored by Sandy Willard, Keane’s Vice President of Corporate Asset Recovery, originally appeared on the Unclaimed Property Professional’s Blog.
If you’ve seen the show “Storage Wars”, you know from the tagline of the show that “when storage units are abandoned, the treasures within are put up for auction.” In the unclaimed property world, there is no big reveal that exposes what one would classify as a treasure. Holders of tangible unclaimed property typically spend a lot of their time sifting through items with little or no value; like papers, clothing, etc.
Tangible property is interesting in that the regulations dictating holder responsibilities are often vague or incomplete, such as guidelines outlining how to liquidate property and what to do with items not reportable to the states. Like intangible property, tangible property comes in many forms and varies by industry. The most common type of tangible property is contents found in safe deposit boxes held by banks and financial institutions. Hotels, schools, museums, and hospitals are also common reporters of tangible unclaimed property.
At the 2014 UPPO Annual Conference, March 23-26 in Grapevine, Texas there is a session designed to answer the common questions that arise when dealing with tangible unclaimed property. Attend the session Safe Deposit Boxes and Beyond: The Storage Wars of Unclaimed Property to learn answers to the following questions; “What are reportable items?”, “How do I deliver the items to the state?”, and “What do I do with the unwanted items?”
What are reportable items?
Each state has a list of items it wants the holder to report and remit. Holders can find such lists on states’ websites. Some states, like California, require a holder to report all contents found in a safe deposit box, whereas, New York only wants military medals and face value cash found in the boxes.
How do I deliver the items to the state?
The approaches to delivery requirements vary by state. Some states, such as Florida, provide very specific instructions for the delivery of tangible property. Others are not so defined. There are states, such as Connecticut, that require holders to liquidate all tangible property of value and remit the proceeds, minus specific expenses due the holder. Other states, such as New York, allow non-reportable safe deposit box contents to be liquidated, but do not require it. By requiring or allowing the holder to sell tangible properties, states are able to obtain the cash from liquidations, but pass the burden and expense of handling, storing, and liquidating actual objects to the holders.
What do I do with the unwanted items?
Creating a company policy and procedure of how to handle unwanted items will help alleviate holders of the uncertainty and space burden tangible items bring. Identifying how long to keep the tangible items, proper documentation, and record retention are all issues to address in the policy and procedure.
For more in-depth discussion of these questions and the issues holders of tangible property face, attend the session Safe Deposit Boxes and Beyond: The Storage Wars of Unclaimed Property at the 2014 UPPO Annual Conference, March 23-26 in Grapevine, Texas. Register today!
About the Author
Sandy Willard, Vice President and Corporate Asset Recovery Manager at Keane, is a co-presenter of the session Safe Deposit Boxes and Beyond: The Storage Wars of Unclaimed Property. Sandy has over 18 years of experience in the unclaimed property industry. She managed unclaimed property reporting at Wachovia Bank. During that time she led the effort to consolidate unclaimed property reporting for Wachovia and its subsidiaries into a centralized location, and led a project to liquidate safe deposit box contents in states that do not accept tangible properties and/or require their liquidation. Sandy also designed and implemented procedures to recover escheated funds, including the recovery of funds prior to escheatment, funds held at state and federal agencies and courts. Contact Sandy Willard at [email protected] or 646-770-9216.