By Andrew Perrine
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.
- Texas and Michigan decided to have their deadlines on the first of July.
- Delaware and Connecticut have deadlines in March.
There are many other exceptions and peculiarities that need to be accounted for to ensure unclaimed property compliance. At FSI we closely monitor changes in laws, administrative rules, and unclaimed property policies for all North American jurisdictions that have unclaimed property laws.
If you don’t have the bandwidth to go it alone, contact us to learn more about FSITrack, our unclaimed property reporting software.