Category: Unclaimed Property

Filing Deadlines

As you embark on creating an unclaimed property program, one of the most important elements is simply knowing when to file. It would be so convenient if all states and territories required the same deadline (say, April 15th), but that is not the case. Further complicating matters is the fact that some jurisdictions require different filing dates for different property types. To top it off, states are free to change their policies at any time, as Tennessee just did, switching from a May to November filing date. Keeping all of this straight can be a headache, and filing at the wrong time gives governments the opportunity to assess penalties and interest.

The deadlines do follow some general patterns. A majority of states have filing dates at the end of October or the beginning of November. The states that require life insurance property to be filed separately generally set the deadline at the end of April or the first of May. Here are some notable exceptions:

  • New York has nine separate deadlines depending on the business or property type.
  • In California a business organization’s end of year may vary, but the report due date will always be June 15th, except for life insurance property, which is due December 15th.
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Dormancy Periods

Being familiar with the applicable dormancy periods is crucial for a successful unclaimed property program. A dormancy period is the length of time that you must hold a property before escheating it to the state, and it typically begins on the date that the funds were first payable. Of course every state has a different set of dormancy periods, and of course they are all subject to change.

The standard dormancy period is three years for most states, but over a third use a five-year standard. Certain property types often have longer or shorter dormancy periods. For example, government-related funds and utility deposits often have shorter periods, typically a year. The majority of states also use a one-year dormancy for payroll and commissions. Money orders and travelers checks almost always have longer dormancy periods.

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