On February 27, 2018 Georgeson’s Unclaimed Property Consulting team hosted the second in a series of national unclaimed property forums in Columbia, Maryland.
Pam Wentz, the National Practice Leader of Georgeson’s unclaimed property consulting team welcomed a full house, followed by three and a half hours of education. Attendees were provided with a variety of unclaimed property knowledge for beginners and seasoned practitioners. Special guest Val Jundt, Independent Unclaimed Property Specialist, was also on hand for an introduction to unclaimed property and moderation of a state panel. Representatives from Maryland, Pennsylvania, and the District of Columbia each presented updates from their respective states.
In addition to the introduction to unclaimed property, sessions were also offered on unclaimed property reporting, audit updates, voluntary disclosure options, and best practices. Key takeaways from these sessions include:
- Written policies and procedures are critical for a successful compliance program.
- Not tracking the correct contact from owners is one of the most common errors in unclaimed property reporting.Audit notices should be taken seriously. A Non-Disclosure Agreement (NDA) should be signed at the onset of the audit.
- Not every state offers a Voluntary Disclosure Agreement (VDA) but most states have either a formal or informal VDA program (California does not offer a VDA).
- Best practices include having a process for merger and acquisition due diligence.
- The bottom line is that ignoring unclaimed property compliance is no longer an option for companies.
Eric Eichler, Maryland Unclaimed Property Manager, shared information regarding the state’s electronic reporting instructions. Holders of unclaimed property need to have their Maryland unique holder number available when filing electronically, in addition to the access code which is a personal identification number created by the holder to access the report at a later date. The state encourages holders to include as much information as possible for each owner when entering their property, and to always mail a copy of the confirmation page and remittance advice slip page with all reports.
Brian Munley, Director at the Pennsylvania Treasury Department, reported on the recent policy guidance change in standards for business associations (securities). Effective immediately, Treasury requires that a dual threshold be satisfied before reporting property under Section 1301.6(2) and (3). Before property is deemed abandoned, the following conditions must be met:
- The holder must have “lost contact” with the owner; and
- The owner has not expressed any indication of interest (activity) for a period of three years.
Lynn Hall, Interim Manager of Unclaimed Property for the District of Columbia, shared that the District of Columbia just rolled out a new electronic online reporting and payment process. The new site has only been live for a couple of weeks but will allow holders to file and pay remittances online. It will also have the ability to match a holder’s payments to their reports. In addition to holders being able to file and remit electronically, owners can also file claims electronically. The District’s online instructions have not been updated yet but are expected to be published within the next two weeks. Many of the holder forms have been eliminated since DC now wants everything sent online.
The next in the series of national unclaimed property forums is in Houston on May 16. Learn more about the national roadshow.
About Georgeson Unclaimed Property Services
Georgeson's unclaimed property services cover the unclaimed property lifecycle, relieving organizations of these complex and resource intensive tasks. Our solutions include unclaimed property analysis and consulting services, annual unclaimed property reporting, owner location services, shareholder and PostMerger CleanUp™ services.
Our clients choose us because of our high quality service to both the company and individual owners. We take pride in helping organizations satisfy state abandoned property requirements, reducing corporate servicing costs, escheatment obligations, fraud and audit risk.
For more information, please contact Mike Ryan at 201-208-9192 or by email at mryan@georgeson.com.
