Tag: deadlines

2020 sure has been something, and the fun isn’t over yet: the big fall deadline for unclaimed property reports is fast approaching, but this year October 31 and November 1 fall on a Saturday and a Sunday respectively. Will this cause any changes to your unclaimed property reporting process?

If all has gone according to plan, no. In general, as long as you have given sufficient time for owners to respond to your due diligence mailing, you can file your unclaimed property report any time between now and the end of October. For those that like to take it closer to the wire, most jurisdictions will allow reports to be submitted on November 2, without penalties or interest.

However, there are states that are not so lenient, and require the report to be in their office on October 30th, the Friday before the weekend: Arkansas, Idaho, and Washington.

Nevada, which is an online-only state, requires the report to be submitted no later than Saturday, October 31.

Iowa, Indiana and Wyoming require that the report be postmarked by Sunday, November 1, while North Carolina requires the report to be in their office by November 1.

Finally, here are the states that I have personally confirmed will accept reports on November 2: AK, AL, AZ, CA, DC, GA, IL, KS, KY, MA, MD, ME, MO, MS, MT, ND, NE, NH, NJ, OH, OK, OR, SD, TN, TX, UT, WI, WV.

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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