Fall filing isn’t months away, it’s weeks away…
If you’re a holder with unclaimed property obligations, the clock is already ticking. Most states with November 1st deadlines require due diligence mailings well before the filing date. That means if you wait until October, you may already be behind.
At UPCR, we see holders face the same recurring challenges every year. With deadlines looming in key states like Delaware, Illinois, and Georgia, now is the time to get organized before missed mailings, formatting issues, or dormancy missteps create compliance headaches.
Key Fall Deadlines & Important Things to Note
Delaware
November 10th Filing Deadline
Due diligence notices must be mailed 30–120 days before reporting. As the state of incorporation for many U.S. companies, this deadline is one of the most scrutinized in the country. Missing it can significantly increase audit exposure.
Illinois
November 1st Filing Deadline: banks, insurance other than life, government entities
Applies only to these holder types. Other holders file in the spring.
Georgia
November 1 Filing Deadline
Due diligence letters must be mailed 60–120 days in advance of the report. Letters must be sent by first-class mail unless the address is invalid.
Arizona
November 1st Filing Deadline
Requires due diligence 120 days before reporting if statutory thresholds ($50) are met.
Ohio
November 1st Filing Deadline
Due diligence is required 60–120 days before reporting. Ohio also requires all holders to file electronically through the state’s portal (Ohio Business Gateway).
Virginia
November 1st Filing Deadline
Due diligence mailings are required 60–120 days before reporting. Virginia law imposes a civil penalty of up to $50 per account if due diligence isn’t performed, which can add up quickly for holders with large volumes of reportable property.
New Mexico
November 1 Filing Deadline
Mailings must occur 60–120 days before reporting, and holders must attempt owner contact at the last known address.
California
Notice Report Due November 1st
California has a two-step reporting process. The Notice Report is due before Nov. 1, followed by a six-month due diligence window. The Remit Report is then due the following June. This staggered timeline often surprises holders who assume all filings align with the November 1 calendar.
Mistakes Holders Make Every Fall
Waiting Too Long to Send Due Diligence Letters
Many holders assume they can wait until the report deadline, but most states require mailings 60–120 days in advance. For November filings, that means notices should already be in the mail by early September. States also generally require that owners be given at least 30 days to respond before funds are escheated to the state. Waiting too long shortens that window and risks noncompliance.
If you’ve missed the due diligence window, don’t assume you’re out of options. States like Illinois allow extension requests if filed 15 days before the deadline. Filing late without disclosure creates risk but applying for an extension can help mitigate penalties.
Relying on Outdated Letter Templates
Reusing the same template year after year is risky. States often update the required language, response deadlines, or formatting.
For example, Massachusetts (fall filing state) requires that letters not only describe the property but also explain that state law requires holders to remit unclaimed property if owners do not respond. Illinois requires due diligence notices to include a statutory heading with specific language. Using an outdated template can render your due diligence invalid, even if you mailed on time.
Assuming Every State Has the Same Rules
No two states approach unclaimed property reporting in exactly the same way. Georgia requires certain fields in electronic reports that don’t appear in other states. Michigan requires life insurance companies to file in the fall, while other holders report in the spring. And Delaware applies heightened scrutiny to corporate reports.
That’s why UPNavigator® includes ongoing rule updates, giving holders a single place to view the most current requirements without combing through individual state sites.
Reporting to the Wrong State
Another common mistake is assuming all property should be reported where the company is located. In reality, reporting follows the owner’s last known address.
For example, if you have property owed to 10 owners in 10 different states, you may need to file in all 10. Only when there’s no valid address on file does the holder’s state of incorporation apply. Misunderstanding this rule leads to underreporting, duplicate reporting, or misdirected property — all red flags in an audit.
Overlooking Dormancy Differences
Dormancy periods often vary by property type:
- Wages: often reportable after just one year of inactivity
- Vendor credits: typically 3–5 years depending on the state
- Securities: often three years, though some states differ
- Gift cards or loyalty points: exempt in some states, reportable in others
It’s important to apply these rules carefully, since misapplying a three-year dormancy standard across the board is one of the most common audit exposures. In New York, pending legislation (S4109) would extend the dormancy period for many accounts from three years to five, underscoring how quickly these standards can change.
Confusing Fall vs. Spring Deadlines
Not every state follows the November 1 cycle. Some property types, like life insurance in Texas, are reported in the fall, while most other property categories in the state are due in the spring.
Arizona is the reverse — most holders file by November 1, but life insurance companies report in the spring (May 1).
California adds another wrinkle with its dual-report system: a Notice Report before Nov. 1 and a Remit Report the following June. Holders who don’t plan for staggered deadlines often scramble to catch up.
How to Prepare Now
Find Reportable Property
Start by identifying property that meets dormancy and reporting criteria:
- Wages: often reportable after one year
- Vendor credits: typically 3–5 years depending on the state
- Securities: often three years unless a state specifies otherwise
- Gift cards/loyalty points: exempt in some states, reportable in others
Confirm the reporting window. Most states follow a three-year standard, meaning for 2025 filings you should review property last active in 2022. Reviewing only last year’s activity will cause you to underreport.
Run Reports Early
Don’t wait until October. Running reports now allows you to validate addresses, review balances, and resolve exceptions. UPNavigator® automates this by generating reminders when due diligence windows open and flagging accounts that need attention.
Update Your Due Diligence Letters
Check whether your templates align with current requirements. Some states dictate details down to formatting — California, for instance, requires a statutory heading in bold, minimum 12-point type. Others mandate statutory language, and nearly all require a clear response deadline. A one-size-fits-all letter rarely satisfies multiple jurisdictions.
Check State Formatting Rules
Each portal has quirks. Illinois requires negative reporting, while Virginia and Arizona expect different file structures. Small formatting issues can cause rejected reports or late filings, problems that can even trip up otherwise prepared holders.
Lean on Expert Help
If your team is stretched thin, consulting or outsourcing can relieve the pressure. At UPCR, we help holders validate data, apply correct dormancy logic, and manage the due diligence process so filings are accepted the first time.
Stay Ahead This Fall
We’ve created a Fall Filing Readiness Checklist with deadlines, mailing timelines, and practical tips to guide your reporting process.
Need help reviewing your data before November? Let’s make sure you’re covered before the rush. Taking action today means smoother filings — and fewer surprises — tomorrow.