Unclaimed property update: Deadlines approaching in a few states, WA makes changes

Unclaimed property reporting can easily trip businesses up, landing them in the audit crosshairs of state governments and possibly leading to penalties and interest.

In addition to all 50 states, Washington D.C., Puerto Rico, Guam and the U.S. Virgin Islands also have statutory-required reporting of unpaid financial assets, such as wages, refunds, uncashed checks, overpayments, gift card balances, securities, etc., that are due to their residents.

California’s unclaimed property reporting and remittance period wrapped up a few short weeks ago. Meanwhile, the big deadlines for Michigan and Texas are coming up July 5, 2023. In most years, that deadline date would be July 1, but it falls on a weekend this year.

Massachusetts’ June 30 deadline for reporting tangible property abandoned during the previous year is coming up even faster.

New York has a complex, rolling unclaimed property reporting and payment schedule. A few upcoming deadlines to note:

• First business day in July: vehicle and traffic law refunds
• July 10: collateral loan brokers, and
• September 10: insurance companies, including life insurance companies (most states have a May 1 deadline for life insurance companies) and public assistance.

Unclaimed property rule changes in Washington

Washington’s deadline remains October 31. However, the Evergreen State enacted a Revised Uniform Unclaimed Property Act this year. Here are the important things to know:

• Due diligence letters must be sent out to owners of any unclaimed property valued at $75 or more, and what you put in your letter (and email correspondence if they’ve given consent to receive email from you) matters. For what’s required, click here.
• If you have multiple addresses for a property owner, the state with the most recent address may take custody of the property. If the most recent address is temporary, the state with the next most-recent non-temporary address may take custody. The law has a new definition of “domicile.”
• In the fall of 2023, property held by government agencies and courts, with last activity dates between July 1, 2020 and June 30, 2022, is due to be reported on or before October 31, 2023.
• The deadline for insurance companies is now April 30.
• The broker and account numbers for reporting unclaimed securities and mutual funds have changed. More details can be found by clicking here.