KeepUP™ Blog

6/30/22 12:29 PM

Update: Delaware VDA Invitations To Mail On Or About July 22, 2022

The Delaware Secretary of State (SOS) has indicated its intent to mail the latest round of VDA invitations on or about July 22, 2022.  Under Delaware law, the state cannot initiate an unclaimed property examination (audit) unless a company has first been notified in writing by the SOS that it may enter the SOS VDA Program. Holders who do not enroll in the VDA Program within the 90-day notice period set forth in the letter will be referred to the Department of Finance for an unclaimed property audit.


Topics: Delaware

5/3/22 8:27 AM

WV H 4511 Enacted – Upcoming Changes for Fall 2022 Unclaimed Property Report

The West Virginia State Treasurer’s Office (WVSTO) recently confirmed that holders will need to follow the changes made to their unclaimed property law as a result of the passage of House Bill 4511, which becomes effective June 10, 2022, for the upcoming Fall reporting cycle.

This short turnaround time for holders to become compliant with the new law highlights the need for holders to actively monitor legislative, regulatory, and administrative activity.


Topics: Compliance, Reporting

4/14/22 9:50 AM

Reduce Escheat Liability with Owner Reunification Programs.

If your organization places a value on customer retention and would like to reduce your overall escheatment and due diligence expenses, now is the time to commence an outreach program to dormant account owners. There is still time to make contact with customers prior to the fall escheatment cycle, and if you move quickly, you can also reduce your due diligence mailings expenses. 

Due diligence for the fall reporting cycle generally mails anytime from July – August. The due diligence mailing process cleans up a handful of accounts every escheat season – usually somewhere between 10 -20%. However, as the below chart demonstrates, a proactive outreach program that begins far in advance of the due diligence time frames can significantly reduce the population of accounts that are ultimately escheated.


Topics: Due Diligence, Best Practices, Owner Reunification

4/1/22 10:23 AM

Unclaimed Retirement Update: SECURE 2.0 Picks Up Steam, Passes House

On March 29, 2022, the U.S. House of Representatives voted almost unanimously in favor of SECURE Act 2.0, also known as the Securing a Strong Retirement Act (H.R. 2954). SECURE Act 2.0 expands upon the retirement savings solutions set forth in the SECURE Act, which passed in December 2019.


Topics: Compliance, Reporting, Best Practices

3/22/22 1:13 PM

Meet MarketSphere at the UPPO 2022 Annual Conference

The UPPO 2022 Annual Conference is live this year in Orlando, FL on March 27th – March 30th. This is the only conference of its kind that focuses specifically on organizations (holders) and their unclaimed property compliance needs.

The conference attendees include new and seasoned professionals. Everyone will have the opportunity to meet with each other and talk with unclaimed property experts from several exhibiting companies.


Topics: Best Practices

3/15/22 8:58 AM

MarketSphere Announces the Promotions of Unclaimed Property Experts Michael Lazar and Bill Berger

MarketSphere Unclaimed Property Specialists, providers of advanced unclaimed property managed solutions, is pleased to announce the promotions of Michael Lazar to Director, Corporate Asset Recovery Practice Leader and Bill Berger to Director, Owner Reunification Practice Leader. These promotions reflect the growth of the firm and the depth and breadth of its leadership team.


Topics: Best Practices, Corporate Asset Recovery, Owner Reunification

3/8/22 10:39 AM

It Pays To Be Proactive When Searching for Unclaimed Life Insurance Owners

Life insurance benefits can go unclaimed for several reasons, such as if the insurer loses contact with an insured, is not aware that an insured has died, or is unable to locate any beneficiaries. Both the insurance laws and the unclaimed property laws require the reporting and remitting of unclaimed life insurance proceeds, and life insurance companies must be mindful of the requirements in each state, which continue to evolve.

As states actively enforce their unclaimed property laws by way of audits, self-reviews, and questionnaires (often with the assistance of a third-party auditor), insurance companies are not immune. A recent investigation by the New York State Department of Financial Services into one life insurer’s practices has led to a settlement under which the insurer must pay upwards of $10 million in restitution and penalties for the failure to pay unclaimed life insurance proceeds in accordance with New York law.[1]


Topics: Compliance, Due Diligence, Best Practices, Owner Reunification

2/18/22 2:15 PM

CA AB 2280 (Re)Introduces an Unclaimed Property Voluntary Compliance Program

We recently posted about CA AB 466, which became effective on January 1, 2022, authorized the Franchise Tax Board (FTB) to share information with the State Controller’s Office (SCO) related to compliance with California’s unclaimed property law. As a result, businesses must now provide the following information on business tax return forms:

• Has the entity previously filed an unclaimed property report with the SCO?
• If so, what was the date of the most recent report?
• What was the amount last remitted?

On February 16, 2022, a new bill was introduced in California, AB 2280, wherein the Legislature again references the FTB, estimating that since 2020, approximately 1.3 million business that have filed taxes with the FTB have failed to report unclaimed property to the state.


Topics: California, Reporting, Voluntary Disclosure Agreements

2/15/22 8:25 AM

Unclaimed Property Reporting Extensions - Get Your Request in Soon!

With Spring reporting due dates around the corner, holders are busy reviewing due diligence responses, and updating and reconciling their files. But what if a holder is already aware that they will not be ready to file timely reports to the states?   While businesses continue to feel the strain of the pandemic, in the form of staffing shortages and postal service disruptions, holders may also experience other business interruptions that could lead to reporting delays, including implementing new accounting systems, changes to transfer agents or other personnel changes, or undergoing a merger or acquisition.   In these cases, it is worthwhile to consider whether a reporting extension is available.


Topics: Compliance, Reporting, Best Practices

2/8/22 9:33 AM

Unclaimed Property Outreach from Delaware & the District of Columbia

The next scheduled rounds of invitations to enroll in the Delaware Secretary of State’s (SOS) voluntary disclosure program are expected to be sent on February 18, 2022, and then again on May 20, 2022.

 Under Delaware law, the SOS must first notify the holder in writing that it may enter the VDA program prior to initiating an unclaimed property examination (audit). Holders who do not enroll within the 90-day notice period will be referred to the Department of Finance for audit.

If your company is incorporated in Delaware or has significant operations in Delaware, be on the lookout for these letters, or any letters from either the Secretary of State or the Department of Finance.


Topics: Delaware, Compliance, Best Practices, Voluntary Disclosure Agreements