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Looking for escheat laws for each state? Get started with our guide to state unclaimed property laws.

Subscribe to Keanotes®: Stay Up to Date with Unclaimed Property News, Laws and Trends

Escheat laws by state can be difficult to keep track of, as no two states interpret unclaimed property in the same way. State escheatment laws can differ based on a variety of factors, including property type, dormancy period, and compliance requirements, among other factors.

Keanotes®, our industry leading compliance journal, eases the burden of tracking the various escheat laws by state by providing an in-depth view and analysis of unclaimed property regulations and state escheatment laws. Keanotes also includes editorial coverage of ongoing legislation changes, legislative summaries of escheat rules by state, guest columnists from state and industry professionals, Q&A sessions, continuous interpretation and recommendations to effectively comply with unclaimed property laws while increasing your company’s bottom line.

The compliance experts at Keane can help to keep you up to date the various escheat laws by state by providing real-time alerts when significant changes are made to unclaimed property regulations and state escheatment laws. Subscribers to Keane’s Unclaimed Property Compliance Portal will also receive access to view additional details on the legislative change, including a summary of the legislation and an analysis of its impact.

Click on the button below to register for Keanotes®. You’ll receive a notification when new issues are published and real-time alerts for changes in escheat laws by state. For information on subscribing to Keane’s Unclaimed Property Compliance Portal, please visit www.keanecompliance.com.

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Contents of Latest Issue

To Self-Assess or be Assessed Interest – This is Now the Question

Heather Gabell, J.D., Director of Compliance

The New York trial court’s recent denial of JP Morgan Chase & Co.’s motion for summary judgment in New York ex. rel. Raw Data Analytics LLC v. JPMorgan Chase & Co. [1] has caused a stir among holders in all states.

Industry Table Talk: Transfer Agents Discuss Unclaimed Property

By John Buonomo, Executive Director AST, Rob Franz, Senior Director - Compliance, Broadridge, John Ulla, Chief Operating Officer, Continental Stock Transfer & Trust

Unclaimed property poses a unique challenge for transfer agents as many investors and shareholders do not understand that if they do not vote proxy, cash their dividend checks or log into their account then their account becomes dormant and eventually remits to the state.

Where Liability Lies: Third-Party Administrators and UP Compliance

By Laurie Andrews, Director of Consulting

When using a TPA, the question becomes, who is responsible for escheatment. The only way to know is to pull out the contract and read through it carefully.

KUPS Update: Keane Unclaimed Property System

By Joe Pollock, Vice President of Reporting

Keane Unclaimed Property System (KUPS) is progressing as scheduled and we’ve made some exciting new advancements.The Fall 2019 reporting cycle was the first in which Keane ran KUPS in a production environment.

Audit Update: Texas

By Alex DeFruscio – Vice President, Sales & Gary Joseph – Senior Manager, Consulting & Advisory Services Team

TX CPA has issued hundreds of audit notices over the past couple years, with many issued in the last quarter of 2019. As suspected, holders in the oil and gas industry are still a focus.

Buried Treasure

By Paul MacCready

There’s a corporate version of that kind of buried in plain sight treasure and it’s actually more common and easier to find…if you know where to look.

Texas House Bill 3596

By Gary Joseph – Senior Manager, Consulting & Advisory Services Team Heather Gabell – Director, Compliance

On June 10, 2019, Texas House Bill 3598 was enacted. The bill changes the way holders report unclaimed property to the State, and expands the Texas Comptroller’s (“TX CPA”) legal options of enforcement.

Virtual Currency Update

By Heather Gabell, Director of Compliance

The verdict is still out whether virtual currency is ever due and payable, and if virtual currency providers have the necessary control over these assets to remit them to the state even if they do have the obligation to report them as unclaimed.

VDAs – Not Just for Delaware

By Laurie Andrews, Director of Consulting

There are states that do not have a formal program. For lack of a better term, we’ll call them the ‘informal’ VDA states.

RUUPA Round Up

Keane Compliance Team

The 3 most recent adopters of RUUPA are Nevada, to an abbreviated extent, followed by Main and Colorado (in terms of their effective dates). The chart below highlights the major departures from RUUPA.

Holders Eagerly Await News from the IRS and Treasury

By Heather Gabell, Director of Compliance

On November 21, 2019, NAUPA submitted a letter to the IRS and Treasury, expressing its concerns with respect to the withholding and reporting of IRAs. NAUPA expressed concerns similar to those raised by SIFMA and the Holder’s Coalition, and urged the IRS and Treasury to issue additional guidance or provide an extension for compliance with the Revenue Ruling.

Litigation Update

Heather Gabell, J.D., Director of Compliance

Taking a look at State of Delaware ex rel. William Sean French v. CVS Health Corporation, et al. and Yee v. ClubCorp Holdings, Inc. – Remand Order

Keane Expertise Spotlight: Debbie Zumoff, Executive Advisor

By Katie Peirce

Since joining Keane in 1984, Debbie Zumoff has earned the title of being one of the company’s most experienced, knowledgeable and longest tenured employees.

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