Christa DeOliveira's blog

Spring Reporting Cycle Is Just Around the Corner – 7 Tips for Successful Reporting

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Christa DeOliveira Christa DeOliveira, CIA, CCEP

With the fall reporting season behind us and the hustle and bustle of the holiday season upon us, it could be easy to lose sight that the spring reporting season, especially due diligence activities, is just around the corner.  To survive and thrive through another reporting cycle here is a quick guide for successful reporting:

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TRACKER® Unclaimed Property Compliance: What is new?

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Christa DeOliveira Christa DeOliveira, CIA, CCEP

The latest release of TRACKER®, available on September 4, 2013, contains a host of compliance updates. Compliance updates are vital in the ever changing unclaimed property arena and are essential with assisting to keep our users on top of unclaimed property compliance. As might be expected there are a number of typical changes including dormancy period changes, activations and deactivations of property ID codes, state contact information updates, mailing address changes, and functional enhancements.

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Update on States Adopting Legislation Related to Unclaimed Life Insurance Benefits

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Christa DeOliveira Christa DeOliveira, CIA, CCEP

As noted in several previous blog postings, states are passing legislation related to unclaimed life insurance benefits.   The common link of these laws is that they have provisions requiring searches using the Social Security Death Master File (SSDMF).  Specifically requiring for life insurers to conduct searches comparing the SSDMF to insureds of in force policies and retained asset account owners to identify matches.  For any potential matches identified there are requirements to make efforts to find the beneficiaries, to confirm the death of the insured, and assist beneficiaries in claiming any applicable policy proceeds or retained asset account amounts.  Another similar theme is the laws generally include references to policy information that would be necessary to complete a successful search, such as SSN, complete name, date of birth, beneficiary designation, etc.

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Are you in the Know? Uniform Law Commission Study Committee Update

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Christa DeOliveira Christa DeOliveira, CIA, CCEP

The Uniform Law Commission’s Executive Committee appointed a Study Committee to consider whether it would be advantageous to review and revise the Uniform Unclaimed Property Act, as previously reported in Possible Revisions to the Uniform Unclaimed Property Act.

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States Passing the “Model Unclaimed Life Insurance Benefits Act” and Similar Legislation Continues

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Christa DeOliveira Christa DeOliveira, CIA, CCEP

As noted in previous blog postings, It’s Similar to Unclaimed Property Compliance… and Goings on in the Life Insurance Sector, states are adding new laws many of which are based on NCOIL’s “Model Unclaimed Life Insurance Benefits Act” or at least contain similar provisions.  While these laws are generally not directly a part of unclaimed property law, but rather insurance statutes, the laws remain significant and are at minimum indirectly tied to unclaimed property.

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Verification Checklist Phrasing for Louisiana to Change

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Christa DeOliveira Christa DeOliveira, CIA, CCEP

Louisiana’s unclaimed property statutes require for Louisiana to pay interest on any item that was interest bearing while on the books of the holder. Specifically, Louisiana Revised Statutes 9:163 contains the following:

"If the property was interest bearing to the owner on the date of surrender by the holder, the administrator shall pay interest at a rate of five percent a year or any lesser rate the property earned while in the possession of the holder. Interest begins to accrue when the property is delivered to the administrator and ceases on the earlier of the expiration of ten years after delivery or the date on which payment is made to the owner."

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Possible Revisions to the Uniform Unclaimed Property Act

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Christa DeOliveira Christa DeOliveira, CIA, CCEP

By now you may have heard the Uniform Law Commission's (ULC) Executive Committee has authorized the appointment of a new Study Committee for amending or revising the Uniform Unclaimed Property Act (UUPA). This does not come as a surprise as there have been rumblings about the need/desire for revisions for a few years now.

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It’s Similar to Unclaimed Property Compliance…

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Christa DeOliveira Christa DeOliveira, CIA, CCEP

Here are several things that closely approximate unclaimed property compliance although they are actually not part of unclaimed property law and therefore, not regulated by states’ unclaimed property divisions. Regardless, it is useful for unclaimed property professionals in applicable industries to be aware of the legislative activity surrounding the Model Unclaimed Life Insurance Benefits Act and similar legislation; and also the scope of SEC 17Ad-17 expanding as they are significant and are tied to reducing and preventing unclaimed property.

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Delaware Strives to Increase Unclaimed Property Compliance by Launching a New VDA Program

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Christa DeOliveira Christa DeOliveira, CIA, CCEP

Delaware’s Senate Bill 258 was signed on July 11, 2012 and will remain in effect through July 1, 2015. This law sets up a new business-friendly Voluntary Disclosure Agreement (VDA) process where companies have a limited window of opportunity to “catch up” on any past due unclaimed property reporting obligations to Delaware. This law provides for this new program to be administered by Delaware’s Department of State, rather than State Escheator.

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Unclaimed Property Compliance, One More Useful Step

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Christa DeOliveira Christa DeOliveira, CIA, CCEP

Hopefully, your fall unclaimed property reporting cycle went well and you were done before there could be any possible impacts from Hurricane Sandy. (If your reporting process has been disrupted by Hurricane Sandy, then please refer to the information about NAUPA’s Extension Matrix at http://unclaimed.org/reporting/super-storm-sandy-state-reporting-extension-matrix/

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