Vermont recently provided clarification for holders reporting unclaimed property to the state in Spring 2021. Holders should follow the statute currently in effect (§1247 Chapter 14, V.S.A. Title 27), and should not apply the provisions of the Revised Uniform Unclaimed Property Law (House Bill 550, effective January 1, 2021), until the following reporting season.
The guidance provided by the Office of the State Treasurer states the following:
The new RUUPA guidelines will start for January 1, 2021 and next reporting year. That means the current statute applies to this reporting year and should be followed for all reports sent for the spring reporting season.
Reporting Unclaimed Property to Vermont
Per the state's current Unclaimed Property Reporting Manual, holder reports are due to the Treasurer's Office by May 1st of each year. If May 1st falls on a weekend or holiday, reports are due the next business day. As May 1, 2021 is a Saturday, reports for the year ended December 31, 2020 must be received by May 3, 2021.
Under Vermont’s law, if your records contain an accurate address for an owner in Vermont, and the property value is $50 or more, you are required to send written due diligence notices to owners 60-180 days prior to filing the report. The holder must also affirm that a due diligence mailing was completed in accordance with the law.
It is worth noting that the new law, while not applicable to Spring Cycle 2021 reports, does include, among other changes, provisions that specifically address health savings accounts and custodial accounts for minors, new trigger dates for dormancy, and new due diligence obligations.
Vermont’s holder reporting website currently contains an important notice regarding COVID-19. The notice states that holders who require an extension for reporting will be granted a 30-day extension when requested in writing. Holders who need more than 30 days should also provide the additional time requested in writing (not to exceed 60 days). Requests for extensions should be made via email to TRE.UPCompliance@vermont.gov.
Unclaimed property reporting is crucial to staying in compliance with state unclaimed property laws and is a complex, on-going process. Laws differ from state to state, and as you can see, even from one reporting cycle to the next if there is a law change. If your company needs help coming into compliance or needs assistance in managing your reporting obligations, consider reaching out to an unclaimed property advisor today.
*Content contained in this article is considered accurate as of the publish date.