August 2020 Update: Delaware Requests Unclaimed Property Verified Reports

The Delaware Department of Finance has begun mailing letters entitled “Notice Requesting Verified Report for the Report Year 2019” to companies that have previously submitted unclaimed property reports to the state of Delaware but did not submit a report on March 1, 2020.

The letter requests that the company submit the following documentation to the Department of Finance, within 30 days of the date of the notice:

  • A completed Form of Verified Report for Report Year 2019, as well as a list of legal entities included in the report; and
  • A copy of the company’s unclaimed property policies and procedures.

If a company did not have unclaimed property to report in the 2019 Report Year, the state nevertheless requests that the company confirm this information by returning the a Verified Report form even though under Delaware law, negative (or “zero”) reports are not required (22 DE Reg. 851, § 2.6.2).

The company is also put on notice that the failure to respond within 30 days may result in the enforcement of the penalty provisions under Delaware’s unclaimed property law, as well as any other remedy available to the state under applicable law.

Banking organizations and insurance companies are not likely to receive this mailing at the present time, as reporting due dates are on November 10,, 2020 and December 20, 2020, respectively, but holders should also be aware that a mailing may be coming in the future. Be sure to review your policies and procedures, and your reporting obligations under Delaware law, to ensure compliance.

If your company receives this letter, it is important that you understand your obligations and next steps.

COVID-19 has not only changed our lives but has also put new demands on the states to alleviate sharply reduced revenue streams. We expect that Delaware, and other states, will step up their enforcement efforts to try to lessen the impact.

MarketSphere’s experienced consultants understand the nuances surrounding unclaimed property reporting and are prepared to help your company come into and stay in compliance, not only in Delaware, but in any other state where your company might have an unclaimed property reporting obligation.

Contact Us to schedule a no cost/no risk phone consultation to discuss your escheat concerns and learn about options that are available to address any unclaimed property issue.

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