10 Things You Can Do Throughout The Year To Save Your Sanity During Reporting Season

by Maureen Ferrari 25. September 2017 12:49

Ahh, the Fall. The change of seasons. The air is crisp and the leaves are bursting with color. For those of us who own the responsibility of reporting and delivering unclaimed property to the states, we watch much of the Fall pass us by from our office window.

Unclaimed property compliance is a year-round job, but with the majority of states having a reporting deadline on October 31 or November 1, the Fall reporting season can be an extremely busy time for unclaimed property practitioners. Whether you perform the function in house or outsource, there is a lot of effort and cooperation required to be compliant with all of the deadlines.

For those who like the adrenaline rush of making it just under the deadline, keep doing what you’re doing. For the rest of us, a little planning and preparation goes a long way.

Things you can do year round to make reporting easier:

  1. A calendar/timeline of events is your best friend. Establish a year-long calendar of events or take advantage of the calendar in your reporting software. This will ensure that you hit all of the compliance deadlines for due diligence and reporting.
  2.  Realize that once you stray from the timeline it has can have a snowball effect and push everything closer to, or beyond, the final reporting deadline.
  3. Perform customer outreach early and often. Send courtesy letters prior to the account tolling the dormancy period. Invest in owner location services. You not only have a greater opportunity to reach the customer, you can save due diligence costs in the future.
  4. Ensure that you have policies and procedures in place for paying claims initiated by the courtesy letters or due diligence letters. Consider what will be required to pay multiple owner claims, estates, businesses, foreign owners, etc. Be aware that fraud is pervasive in this area.
  5. Make use of state online resources and holder handbooks to make certain that you have the most up-to-date information for report delivery, making payment and transferring securities, mutual funds or safe deposit box contents. This information can change annually and some states have been known to make updates very close to the reporting deadline. (Que the insanity!)
  6. Utilize the report upload feature on the state’s web site. Be aware that some require you to register or obtain a unique holder ID so don’t wait until the last minute. There may be a lag time between registration and obtaining your credentials.
  7. Be aware that if you need to file an extension, some states require 30 days’ notice. If you have a catastrophic event close to the deadline, many states will cooperate in extending the deadline, though you may have to direct your appeal to the state administrator rather than a staff member. Note that a few states require payment to be made by the deadline, even when filing an extension, and some states will not grant extensions two years in a row.
  8. Prepare to set aside a reserve to pay penalties and interest for property that is being reported late to states that actively assess them. Interest assessments are not always immediate, and can arrive months or years after reports have been reconciled by the state.
  9. Have a plan in place for customers who are late in responding to due diligence notices. (And this will inevitably happen) If you have already locked down your accounts or reported the funds to the state, what is your protocol? Do you refer the customer to the state or do you make the customer whole and seek a reimbursement from the state?
  10. File your report as soon as it is completed. You don’t have to wait until the deadline to file. The states receive thousands and even tens of thousands of reports on the deadline. The earlier they receive your report, the sooner it will be reconciled and made available for your customers to file claims.

For all unclaimed property practitioners, gurus and novices alike, you can’t always foresee the roadblocks that lie ahead but we can be prepared to take action when they get in our way. As they say, “Only someone who is well prepared has the opportunity to improvise!” That is the least we can do to save our sanity during reporting season.

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