June Unclaimed Property Update from Mike Ryan
June is an important and busy month.
June 1 through June 15, 2023
- California remittance report is typically due. Ensure you remove any owner that came forward and include additional interest or dividends that hit the account since you sent the report in October 2023.
- Check out the fine print is in the notes below
June 30, 2023
- June 30, 2023, is the common period end date for states with unclaimed property reports due in the fall
- For Banking this includes key Macha states of Hawaii, Indiana, Maryland, Minnesota, Virginia, Wisconsin and more such as New York and Ohio
July 1, 2023
- Michigan and Texas reports are due*
*July 1 falls on a Sunday – we recommend submitting these reports by Friday, June 30.
June’s Best Practice – What has changed?
June is a good month to review organizational changes and assess how they could impact unclaimed property reporting:
- Did we acquire another company or branches?
- Will we need to report to a new state?
- Did we introduce new business lines?
- Do we have any other new property types to report?
Did you Know? - New York Has a New Regulation
On May 23, 2023, the state of New York has a new unclaimed/abandoned property regulation that requires all holders to validate a death within 90 days of that holder becoming aware of the death. Upon confirmation of the death, the applicable dormancy period commences retroactive to the date of death.
For any questions on this new NY regulation, owner reengagement, or unclaimed property compliance, please reach out to us.
Note: Typically, the remit (final) report is due 06/01 through 06/15, if the notice report was filed on time. If a notice report is filed at a different time, then the remit is still filed "seven months and no later than seven months and 15 days after the final date for filing the report." The state sends holders due date and direct reporting via the 14F Letter.
Note: Do not add property to a remit (final) report, that was not reported on the corresponding notice (preliminary) report.
Note: Do not report property before allowable window- "no sooner than seven months and no later than seven months and 15 days after the final date for filing the report".