Keeping on Top of Unclaimed Property Compliance

Christa DeOliveira Christa DeOliveira, CIA, CCEP

The latest release of TRACKER®, available on September 4, 2012, has a multitude of updates, helping to keep our users on top of unclaimed property compliance. The updates range from dormancy period changes, to the addition and deactivation of property ID codes, to information on new VDA programs, and to functional enhancements. Here are a few compliance highlights of what is encompassed in the version 4.80 upgrade.

Within the last few years, New Jersey passed legislation that made stored value cards (MS12) issued after July 1, 2010 reportable property with a dormancy period of 2 years. This year, New Jersey SB 1928 passed and subsequently was adopted on June 21, 2012. This recent legislation has actually increased the dormancy period to 5 years. (Incidentally, there is further legislation pending that could actually change this again. Naturally, StoneRiver will continue to track this legislation and if necessary, include any additional changes in a future release of TRACKER.)

New York has removed some property codes related to securities and it could be necessary to make adjustments to properties currently loaded in TRACKER. It may also be necessary to make different selections for property to be loaded in the future, to ensure active property ID codes are used. For more information on the current New York security related property ID codes, in TRACKER go to Tables> Property and Dormancy, click on View, and select View by State. Another place to review the active codes is in the Compliance Manual. This can be accessed by selecting Help> Contents> Compliance> Current> New York> Property and Dormancy.

There has been a flurry of formal Voluntary Disclosure Agreement (VDA) programs announced. Delaware passed SB 258, which was adopted on July 11, 2012. This legislation opened a three-year window for holders to enter into VDAs with Delaware and take advantage of reduced look back periods. This legislation is different from Delaware’s previous VDA program in two significant ways: 1) it is codified and 2) the legislation directs claims to be resolved before the Secretary of State, rather than the State Escheator.

Other states that have announced amnesty and VDA programs include:

TRACKER clients can refer to the Technical Bulletin on Lifeline for changes tied to version 4.80. Also, information on Legislative Updates and Compliance News can be found in StoneRiver’s TRACKER Unclaimed Property 3rd Quarter Newsletter, which is also available on Lifeline.

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