This post details an unclaimed property reporting calendar for holders to follow in advance of the fall escheat reporting deadlines. Keane has utilized this timeline to file annual reports on behalf of our hundreds of reporting clients in an efficient and streamlined manner.
We’re already thinking about the fall unclaimed property filing deadlines, even though it’s six months away and we’re still technically in spring. In the unclaimed property world, we’re already looking ahead to make our preparations for the fall cycle over the next six months. The below guide will serve as a high-level unclaimed property reporting calendar as we approach the October and November escheat deadlines.
We’re in May, and at this point in time, 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.
By June, you should have pulled together a population for escheat analysis. For most of our clients here at Keane, we’re conducting the eligibility analysis and determining which accounts are reportable for the upcoming cycle.
While California due diligence letters should have been mailed already and Arizona letters are due by the end of this month, we’re getting due diligence ready for the remaining fall states, including the preparation of the due diligence letter templates for each of our clients.
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 via computer to their account. Capturing and tracking this owner-initiated activity is a key part of the remediation process.
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.
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 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.
At this point, fall unclaimed property reports are due in six months, but who’s counting? We are!
We’re counting here at Keane because this is what we do every day, all day. Assuming you have an obligation to report to the fall states, you should have already prepared 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.
For additional information, we invite you to register for our upcoming fall escheat reporting webinar being held on Thursday, May 11th. This complimentary webinar 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.
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.