Category: Compliance Alerts

Take Action! 2021 DE SOS Unclaimed Property VDA

Delaware is once again stepping up its enforcement and sending targeted letters to companies inviting them to enroll in the DE VDA program. According to the current process, DE can not call an audit without first giving an opportunity for a company to voluntarily enroll in their Voluntary Disclosure Agreement...

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DE SOS Notifying 200 Companies to Enroll in AUP VDA Program

Following protocol, DE SOS VDA Administration is notifying 200 companies in another round of DE VDA notification letters. If your company receives a letter encouraging your company to undergo an unclaimed property self-audit review and enrollment in the DE VDA Program, do not ignore it. If you do not respond,...

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Delaware AUP VDA Letters Mailed: Be Aware and Be Proactive!

Be Aware and Do Not Ignore these Notices... In February 2020, Delaware Secretary of State sent via certified mail over 100 letters inviting companies (holders) to enroll in Delaware's Voluntary Disclosure Agreement (VDA) program.   These notice letters should be taken seriously as they are generally followed by an audit notice...

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Judge rules to pay interest and penalty on late filed unclaimed property!

Judge decides in a historic case that JP Morgan should have paid interest and penalties for filing past due unclaimed property to states. Is your Company in compliance with state unclaimed property laws? Inquire with your legal, tax, and accounting departments. If your company is not in compliance, what could...

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Arkansas Allowed to Liquidate Securities Upon Receipt

AR HB1427; Signed 3/15/2019, effective 3/15/19 This legislation which became effective immediately upon enactment, allows but does not require the administrator the immediate liquidation of securities.  A claimant may choose to receive the securities if they remain in custody of the administrator or they may receive the proceeds received from...

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New Legislation Changing UP Laws for Life Insurers

Life Insurance reporting continues to become more regulated each year. In this session we will look at recently passed legislation effecting Life Insurance reporting in 2 states that will affect your 2020 life insurance reporting.   UT SB70; Signed 3/21/2019, effective 5/13/19 Specifies when a company is deemed to have...

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Colorado and Kentucky Legislation Takes on Gift Cards & Virtual Currency

While one state tightened up its law for pawnbrokers and other secondhand dealers to enhance their record keeping for gift cards and similar products, another state refined its law related to reporting virtual currency. Colorado SB14; Signed 4/8/2019, effective 8/2/19 Requires secondhand dealers who purchase store credits, gift cards or...

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Tennessee “Spring Forward” to Fall AUP Reporting

Tennessee is now a Fall Reporting State! Tennessee SB 2278 (the companion bill to SB 1859) enacted on April 24, 2018, amended Section 66-29-125 of the Tennessee Unclaimed Property Act. The effect changed the reporting dates shifting Tennessee from a spring reporting state to a Fall reporting state. The first...

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Baffled by Delaware’s new VDA Program?

We recently learned that some holders have been contacted by the State of Delaware for a “verified report” after a filing was received. This initiative is a result of the enactment of a new “Compliance Review” process that was part of Delaware’s Unclaimed Property Law Amendment beginning in 2017. Although...

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Compliance Alert – Spring Unclaimed Property Reporting Deadlines!

Just because you are finally finished with Fall unclaimed property reporting, does not mean you can sit back and take it easy. With the New Year, you need to think about the next filing season! Remember there are states that require “spring” reporting, including: • Delaware (3/1/19) • New York...

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Spring into Spring Reporting!

If you aren't already gearing up for 2018 Spring reporting, you better get a "spring in your step" to be in compliance with due diligence and remittance activities for UP reporting for the following states: CT (due 3/31 in non-leap years) DE (due 3/1 for all except financial) FL (due...

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UNCLAIMED PROPERTY FALL REPORTING DUE DATES?   

As you are painfully aware, time is running short to submit your Fall unclaimed property reports to all the states.  If your company reports to all jurisdictions, it is even more time consuming and stressful. Just one of the confusing aspects is the due date for filing the report with...

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BOOOO! Are you ready for October 31st?

No… not Halloween – although that would be more fun! BUT, no trick - this date is important for companies who are required to file and remit their abandoned unclaimed property to the states! A reminder – don’t “get tricked” by making common unclaimed property reporting mistakes like: Writing off...

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