Posted on Feb 19, 2020 by JMS Advisory Group |
This year is a leap year, meaning we all get an extra day in February, but that will only postpone the inevitable unclaimed property compliance burden for 24 hours. In the coming weeks, unclaimed property reports for general corporations (essentially meaning non-life insurance companies) will be due in Delaware, New York, Connecticut, and Pennsylvania – and in that order.
Click on each state name below to jump to its website, and note these helpful tips to consider when preparing unclaimed property reports in each of these states:
Delaware: the first state to ratify the U.S. Constitution in 1787, is also the first state to require reporting in each new calendar year. Reports the State Escheator on or before March 1, 2020 – just a few short days from now! Since a major law change in 2017, Delaware requires due diligence (sending letters to owners) to be completed before filing for any items with a value greater than $50. More details about the reporting process in Delaware can be found in the state’s Holder Handbook.
New York: the home of the original capital of the United States (New York City), requires unclaimed property reports to be the Office of Unclaimed Funds on or before March 10, 2020. New York requires due diligence to be completed by December 10th of the prior year, for any items with a value of $20 or more. More information about unclaimed property reporting in New York can be found in its Holder Handbook.
Connecticut: the state that might be the toughest to get right in a spelling bee requires holders to submit unclaimed property reports 90 days from the presumption of abandonment, which is usually December 31st of the prior calendar year. With the leap year in 2020, that makes Connecticut unclaimed property reports due (must be ) March 30, 2020. Connecticut does not have a due diligence threshold – meaning due diligence must be performed for all items, regardless of value. The Constitution State has a helpful FAQ page on its website for more information.
Pennsylvania: actually a Commonwealth, PA requires holders to have their reports April 15, 2020, a date that might be more familiar to some in the tax world. Due diligence is required for all items over $50, and more helpful reporting information can be found in PA’s Holder Handbook.
For all of these states, unclaimed items that have aged the requisite dormancy period and become “presumed abandoned” in calendar year 2019 will be reportable by the deadlines noted above. Keep in mind dormancy periods vary by property type and each state will impose different reporting rules for each property type – varying dormancy periods being just a single element to consider.
Need assistance? JMS is here to help with all of your unclaimed property compliance needs, large or small. Contact us with questions about reporting, or any aspect of the unclaimed property compliance process.