Keane's Unclaimed Property Blog

An Unclaimed Property Reporting Calendar: What to Do & When to Do It

This post details an unclaimed property reporting calendar for holders to follow each month. Keane has utilized this timeline to file annual reports on behalf of our hundreds of reporting clients in an efficient and streamlined manner.

An Unclaimed Property Reporting Calendar: What to Do & When to Do It

The Fall Reporting Cycle

The fall reporting cycle consists of the bulk of state unclaimed property reporting deadlines, with over two thirds of state deadlines falling on either October 31st or November 1st. The below guide will serve as a high-level unclaimed property reporting calendar and make recommendations on what you should be doing as a holder as you approach Fall reporting deadlines.

May

The fall escheat cycle kicks off in May. At this point, you should be looking at reviewing your policies and procedures to make sure they’re updated for the fall states. If you are using escheat reporting software, review your rules to confirm they are up-to-date.  Ensure any patches and updates received throughout the year from your vendor are applied.

If you are using a home-grown system and updating your software manually, validate the correct dormancy decisions are being applied.

Failing to make critical updates based on state changes could cause you to be out of compliance.

June

By June, Holders should be identifying property that is due in the current reporting cycle, property that is past-due and requires immediate remediation, and forecast any property that might be due to be reported in the future, allowing for proactive remediation well in advance of the due diligence mailings.

While California due diligence letters should have been mailed already and Arizona due diligence letters are due by the end of this month, we’re getting due diligence mailings ready for the remaining fall states, including the preparation of the due diligence letter templates for each of our clients.

July

In July, you should be sending out your due diligence for fall, which will ensure enough time for responses from the owner or their legal representative to be processed. As you send out the due diligence letters and responses are returned, you want to make sure that you’re capturing whatever means by which the person is reaching out to you.

For example, the owner or their legal representative may reach out to you by mail, through your call center, contact you by email, or even log on to their account through an app or online portal.  Capturing and tracking this owner-initiated activity is a key part of the remediation process.

August

To be compliant with most state escheat laws, your due diligence period should conclude at the end of August.  Throughout the due diligence period, you should be processing your responses to due diligence and updating your accounts.  Hopefully you’re reissuing payments to your customers, your vendors, or anyone who has come forward and proven eligibility. Once that is completed, it is time to start the final reporting process.

September

At this point in the unclaimed property reporting calendar, we’re inside of 60 days. September is referred to as “DEFCON 2” here at Keane because all of the deadlines are starting to creep closer. When you’re reporting for as many clients as we are, we can’t wait until October to start our reporting process.

At this point in the process, we are preparing reports and asking clients to confirm the final report totals so that we can prepare your final state reports.   It is important to note if your due diligence is complete and your report is ready to go in September, you can submit your final reports to the state prior to the deadline.

From the state’s perspective, reporting prior to the deadline is great because they’re receiving reports at a not so busy time, giving the report a better chance to be reconciled and uploaded to the state’s database and website sooner. Your customers then have the opportunity to make their claims and your report will not be sitting and waiting with thousands of other reports received by the state.

October

October is “DEFCON 1” at Keane – we get very little sleep and work many nights and weekends. This is the last chance to get your final reports processed and submitted on time.

States require reports to be delivered in a variety of different ways.  Some require them to be burned to a CD and mailed while others require uploads directly to their website. Some states that require the report to be uploaded also require your company to pre-register on their site. Upon registration, you may receive a holder number or identification number that you need in order to upload your report.

If required to pre-register, please don’t wait until the last minute. In the past, we have seen slow registration turnaround times as we get closer to the reporting deadlines.  If the information you need does not get back to you in time, it could cause you to miss the reporting deadline.

What you should have already done.

Assuming you have an obligation to report to the fall states, you should be preparing a database of property for analysis in order to determine what your reportable population is, qualifying your liability, and preparing for your due diligence mailings.

You should also updating your policies and procedures – put this in your plan to do this annually. Make sure that your due diligence template meets all of the state requirements – some states have very specific language that needs to be included in the letters.

Also, if you’re transferring securities to the state, it is critical you have up-to-date transfer instructions.  Some of the states update that information on their website just prior to reporting. We would advise you to look just prior to transfer to make sure that no last-minute changes have been made by the state.

The Spring Reporting Cycle

While the practices and concepts for the Spring reporting cycle are very similar to the Fall cycle, the timing of performing each activity can vary by state, especially for due diligence activities.

In order to meet the mailing timeframes of its due diligence statutes, some states require mailings utilizing data from prior reporting cycles. Those states are referred to as ‘Early Mailing States’ and includes  Arizona (Life Insurance), Arkansas (Life Insurance), California, Connecticut, Delaware, Minnesota, Pennsylvania, and New York.

For the spring reporting cycle, we’ll break out the unclaimed property reporting timeline by separating the ‘Early Mailing States’ and ‘Late Mailing States’ to properly point out when tasks should be completed.

November

With the Fall reporting cycle coming to a close, the Spring reporting cycle picks up, allowing for very little time to regroup.

For companies that are required to report unclaimed property during both cycles, this is the time to remediate any pain points from the previous cycle, implement any process improvements, and revisit any unclaimed property reporting policies and procedures, especially for organizations with a reporting obligation to the aforementioned early mailing states.

Additionally, make sure to apply any new laws or changes in regulations that could affect your reporting outcome. This will help ensure compliance during the reporting cycle.

Holders reporting to California should be conducting their due diligence mailings for the following year’s notice report.

If you do not have an obligation to any early mailing states, you can relax for a month or so, but should look to address any pain point from the previous cycle as soon as possible.

December

December is crucial in determining how your reporting cycle will unfold. For the early mailing states, you should be conducting your escheat eligibility analysis to identify reportable property.

Some states also have due diligence mailing deadlines that need to be met in December. For example, New York requires that letters need to be mailed by December 10th for utility, banking, and insurance properties (life and non-life) and December 31st for securities that involve dividend reinvestment. Additionally, Connecticut and Delaware due diligence mailings need to be sent by December 31st.

It’s important to reach out early in the process if you need assistance, as it will allow plenty of time for due diligence letters to be sent to owners to remediate any reportable or past-due property.

January

Holders should be continuing the due diligence process by processing return responses from property owners, capturing and logging any owner activity to improve your records, and potentially re-issuing payments to located owners.

Again, as we stated during the Fall reporting process, making sure that all applicable owner-initiated activity is tracked and logged is a key part of the remediation process – and can also protect you in the event of an audit.

For the late mailing states, now’s the time to get started. If you haven’t already, you should be revisiting company policies and procedures as well as identifying and remediating any pain points that were uncovered as a result of the Fall reporting cycle.

For additional information, we invite you to view the On-Demand Replay of our latest escheat reporting webinar. This 60-minute presentation will detail escheat reporting best practices and compliance updates for the coming cycle.

February

In the early mailing states (AR, AZ, CA, CT, DE, MN, PA, and NY) it’s time to prepare your reports. To start, you should be reviewing any property that was determined reportable and begin removing any owners that have responded affirmatively as a result of due diligence outreach.

Once reportable property has been sorted, confirm final report totals and begin report preparation. Several states have reporting deadlines in March and April, and if your reports are completed in February, you are allowed to submit them before the actual deadline.

For the remainder of the spring states, you should perform your eligibility analysis to determine reportable property and begin preparations for the due diligence process.

March

The first reporting deadline for an early mailing state is Delaware’s on March 1st, with New York and Connecticut following shortly thereafter. So the activities this month should focus on completing and submitting the reports for states with deadlines in March and April. As you complete your reports, this is a great time to proactively review how the reporting cycle went and implement any improvements for the next cycle.

For those late mailing states, March is for continuing and completing the due diligence process. Again, be sure to process responses, capture activity and reissue any outstanding payments.

April

Five states (PA, FL, VT, IL, TN) have deadlines in April. Use this month to finalize reports in these jurisdictions. Be sure to remove any affirmative due diligence responses from your totals, confirm your report totals, and file and submit your company’s final escheat reports.

Need Assistance Reporting Unclaimed Property? Keane Can Help.

For additional information, we invite you to view the On-Demand Replay of our latest escheat reporting webinar. This 60-minute presentation will detail escheat reporting best practices and compliance updates for the coming cycle.

If you would like to discuss your compliance needs in greater detail, or would like more information on Keane’s annual escheat reporting and compliance services, please contact us by completing this form, or calling us at 800.848.8896.

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Editor’s Note: This post was originally authored in May 2016 and has been periodically updated to provide the most up to date compliance information and reporting best practices.

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