Poor Last Known Address Data Quality Can Lead to Rejected Reports
By Joe Pollock, Senior Vice President of Unclaimed Property Reporting Operations
March 24, 2020
March 24, 2020
Many properties are escheated to a jurisdiction because the rightful owner is disconnected from the property. An inaccurate last known address for the owner is the most common cause of these disconnects. When pre-escheatment efforts and due diligence letters have failed to reunite the owner with the property, do you spend additional time and resources to attempt to correct the address or do you report the property to the jurisdiction as-is? I’m sure everyone reading this is nodding in agreement—you choose the latter. This is the nature of unclaimed property. Data quality plays a significant role in unclaimed property escheatment: there could be a typo in a city; the zip code doesn’t match the city; the address contained State A, the city contained State B and the zip code was for State C.
The Revised Uniform Unclaimed Property Act (RUUPA) provides that property allows for escheat to the jurisdiction associated with the zip code. What happens if the address lists Philadelphia, PA as the city and state with a New Jersey zip code of 08094? What if the city is Philladelphia? Do you correct the typo? These are challenges the industry is faced with when determining eligibility and filing property to the state of last known address. Industry handbooks and unclaimed property laws include multiple references to the requirement to report to the state of the last known address, but there is often no guidance on the proper steps to take when the address is flat out wrong.
An increasing number of states have begun to reject reports for properties that have inaccuracies like those listed above. If you are fortunate, the state will accept confirmation that the reported address is the best address that is available, and no amended reports are needed. On occasion, the state may request that you correct the inaccuracies in the address. If you are less fortunate, the state will reject the property, which has larger ramifications—the property may ultimately be due to another jurisdiction with a shorter dormancy period, thus causing the property to be deemed as past due and potentially subject to fines and penalties.
Without clear guidance from jurisdictions regarding these issues, it’s important to err on the side of caution. For the past year, we have been leveraging the U.S. Postal Service ZIP code database in our new Keane Unclaimed Property System (KUPS) to help identify inaccuracies when there are incorrect combinations of city, state and zip code. Our main goal is to accurately analyze and escheat property to the correct jurisdiction, which allows the rightful owner to search the state where they lived and have the best opportunity to reclaim their property.
 Section 301(1) of the RUUPA provides that “The last known address of an apparent owner is any description, code, or other indication of the apparent owner which identifies the state, even if the description, code, or indication of location is not sufficient to direct the delivery of first-class United States mail to the apparent owner.” Section 301(2) of the RUUPA further provides that “If the United States postal zip code associated with the apparent owner is for a post office located in this state, this state is deemed to be the state of the last-known address of the apparent owner unless other records associated with the apparent owner specifically identify the physical address of the apparent owner to be in another state.” Revised Uniform Unclaimed Property Act (Unif. Law Comm’n 2016).