Preparing for the upcoming unclaimed property fall 2024 compliance season

Summer is winding down and now is the time to prepare for fall unclaimed property compliance as the Oct. 31and Nov. 1 deadlines are quickly approaching. Whether you have just taken on unclaimed property compliance or have been doing it for years, here are five things to keep in mind when getting ready the fall 2024 unclaimed property compliance season:

1. Review all sources of potential unclaimed property

• Common property liability types: Includes, but is not limited to, aged accounts receivable net credit balances, stale dated or uncashed accounts payable and payroll disbursements and dormant saving and checking accounts.
• Industry specific liability types: Industry specific properties can include, but are not limited to, mineral interests and royalty payments, equity positions, bank account balances, life insurance policy proceeds, uncashed money orders and utility deposits.
• Hidden liability types: This may include unreported liabilities acquired from a merger, liabilities from third party administered plans for which the third party does not report unclaimed property on a holder’s behalf or marketing efforts that result in entitlements that have not been satisfied.
• Tangible property types: Most commonly this includes, but is not limited to, abandoned safe deposit boxes.

2. Due diligence

If you have not done so yet, the window of time to send your statutorily required due diligence notification letters to the owners of unclaimed property held by your company is quickly closing. In addition to the strict timing requirements on when the letters must be sent, make sure that your team is following newly adopted legislative requirements impacting the dollar thresholds and content of these letters.

3. Legislative changes

Many states have enacted new laws impacting unclaimed property. For example, in the June Tax Trends update, we covered changes to Nevada’s unclaimed property laws that impact this year’s unclaimed property reports. Make sure that your team understands how the Nevada and other state changes may impact the fall 2024 unclaimed property reporting process.

4. Payment methods

Confirm which forms of payment are accepted by each jurisdiction and which states require electronic payments. If issuing checks, confirm with your internal team how much time is needed to have a check processed. If making an electronic payment to a state, make sure to reconfirm each state’s banking information as this information can change.

5. Electronic reporting

Most jurisdictions require electronic submission of reports, with just a few states still allowing mail-in reports. Be sure and confirm which states require electronic reporting and that your team knows the proper way to submit and document that the correct report has been submitted.

The Baker Tilly unclaimed property team has helped hundreds of organizations with their annual compliance, unclaimed property policies and procedures, voluntary disclosure programs, audit defense, exposure quantification and analysis, merger and acquisition due diligence and gift card and stored value card consulting.

Companies wanting to learn more about the fall 2024 unclaimed property compliance process, new state laws that may impact this year’s reporting or any other unclaimed property related questions should reach out to a member of the Baker Tilly unclaimed property team.

The information provided here is of a general nature and is not intended to address the specific circumstances of any individual or entity. In specific circumstances, the services of a professional should be sought. Tax information, if any, contained in this communication was not intended or written to be used by any person for the purpose of avoiding penalties, nor should such information be construed as an opinion upon which any person may rely. The intended recipients of this communication and any attachments are not subject to any limitation on the disclosure of the tax treatment or tax structure of any transaction or matter that is the subject of this communication and any attachments.