The fall 2018 unclaimed property reporting season is nearing an end. While many corporate tax and accounting professionals who manage this process are scurrying to complete their fall filings, most can see the light at the end of the tunnel.
In many ways, the fall unclaimed property reporting season is intense. Eleven states have final reporting deadlines on October 31, 2018 and California's preliminary reporting deadline shares that date. Twenty-nine states use November 1, 2018 as their deadline. With little uniformity in laws amongst the states, the fall reporting season is all about juggling various due diligence mailing dates and dollar thresholds as well as competing electronic and paper filing and payment requirements. It can be exhausting. The only saving grace of fall reporting: the filing dates are uniform. Making the final filings on November 1, 2018 is quite an accomplishment.
It is natural to put unclaimed property reporting in the rear-view mirror on November 2, 2018 and move on to other tasks. Unfortunately, the reality is that the spring 2019 reporting season begins immediately following the completion of fall reporting. With a filing deadline of March 1, 2019 and a due diligence window of 120 days, Delaware requires action be taken starting November 1, 2018. Puerto Rico follows with a filing deadline of December 10, 2018.
Collectively, ten states are part of the spring unclaimed property reporting season:
- March 1: Delaware
- March 10: New York
- March 31: Connecticut
- April 15: Pennsylvania
- April 30: Florida
- May 1: Illinois, Tennessee and Vermont
- July 1: Michigan and Texas
Although relatively small at ten states, the spring reporting season is extremely complex. The main reason is the handful of filing dates across five months, which leads to a variety of overlap and inconsistent dormancy cut offs and due diligence deadlines.
In fact, the spring states are more inconsistent in their due diligence requirements than in the fall. Six states have $50 due diligence thresholds, with New York and Connecticut set at $0.00 and above, and New York requiring certified mailings for items over $1,000. Pennsylvania and Florida open their due diligence windows on December 15 and 30, 2018 respectively. Of course, that means data must be extracted and tested for dormancy and due diligence eligibility in November 2018.
Many corporate tax and accounting professionals are understandably lulled into the false sense that there is a break between the fall and spring seasons, and that the spring is less challenging. The truth is that unclaimed property reporting has become a year-round effort, and in many ways, the spring is as challenging as the fall season, if not more.
In this light, many corporate tax and accounting professionals will shop for an outsourced unclaimed property solution for 2019 in October, November and December. After all, the fall reporting season is the first experience many have with unclaimed property reporting. They realize that a solution allowing them to do what they do best, and outsource the rest, makes sense based on the hours they spent on fall reporting. And of course, the fourth quarter is an ideal time to budget for a 2019 expense.
Over the years, many of our clients found that the fourth quarter is the best time to obtain executive support for a spring unclaimed reporting solution while the challenges of fall reporting are top of mind.
The Duff & Phelps Unclaimed Property team invites you to contact us to learn more about our cost-effective and highly efficient unclaimed property reporting services.
Our clients enjoy comprehensive outsourced unclaimed property support from our state of the art Center of Excellence in Addison, TX. All services are scalable, allowing clients to retain certain tasks if desired. However, most leverage our full capabilities, including:
- Data extracting and parsing
- Maintained subledger with real-time online access to data and metrics reporting
- Dormancy and due diligence eligibility analysis with exemption review
- Due diligence mailing and response management
- Report preparation with signature
- Filing and payment remittance
When coupled with our asset recovery services, our Unclaimed Property reporting team helps our clients ensure their corporations are fully compliant, while becoming a profit center.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.