Initial Compliance/Periodic Reviews
UPRR’s qualified professionals are able to provide initial compliance assessments or periodic reviews to analyze the effectiveness of an unclaimed property compliance program. UPRR will review applicable state laws, analyze related records and make recommendations for improvement, where necessary. UPRR tackles heads-on the substantial research and analysis required for initial compliance and can identify reportable property types to determine liability exposure for previously unreported property based on applicable “dormancy periods” and state “reach-back” scope.
Policy & Procedure Creation
Following the completion of a compliance analysis, UPRR can create an annual compliance plan for employees to follow. The procedures will address a.) reportable unclaimed property record organization; b.) annual reporting, due diligence, and remittance method selection for compliance with each state’s laws; and c.) periodic review to identify erroneous transactions. Training: UPRR’s personnel can also train employees for you on new compliance procedures and systems.
Due Diligence, Annual Reporting, and Remittance
States often require businesses that hold unclaimed property to perform a certain level of due diligence in an attempt to locate an owner before the funds are remitted to the state. UPRR is familiar with each state’s requirements and is well equipped to handle the production and mailing of these due diligence letters. This service can also include handling returns by the post office, which is often important in determining escheat eligibility. Further, if requested, UPRR can create checks and mail them to respondents of the due diligence letters.
UPPR can also handle annual reporting responsibilities by analyzing records and identifying item slated for escheatment and utilizing our proprietary software to complete the required reports in all states or territories where remittance is due. For states that require “negative” reporting (a statement by the holder verifying that no money is escheatable to that state), UPRR can complete and file those reports as well. Also, UPRR provides its clients the option of having UPRR create and sign state report cover sheets and remittances and filing the cover sheets, remittances, and reports directly with pertinent states. Obviously, these services expand to subsidiaries or affiliated organizations of a parent company that may also need to report.
State Relationships/Interest Abatement
Unclaimed property is a small world, and UPRR has fostered a working relationship with many stateunclaimed propertyadministrators. This permits UPRR to negotiate with the appropriate personnel at each state for various reasons, including the filing of VDA’s and seekingabatement of any interest or penalties that may be assessed for property not reported in previous years.
States have increased their audit effortsto ensure compliance with unclaimed property laws and have become more aggressive in using tactics to challenge the accuracy of state reports. UPRR clients can rest assured, however, that in the unfortunate event that they receive an audit notice from a state or third-party auditor, UPRR can provide support. Finally, in addition to answering questions or providing guidance, UPRR can also assess potential audit liability and can develop strategies to minimize exposure.