UNCLAIMED PROPERTY: STAYING AHEAD OF THE RISK. Presented by: Karen Anderson, Senior Vice President

Transcription

1 UNCLAIMED PROPERTY RECOVERY & REPORTING UNCLAIMED PROPERTY: STAYING AHEAD OF THE RISK Presented by: Karen Anderson, Senior Vice President

2 DISCLAIMER This presentation is provided for educational purposes only. Unclaimed Property Recovery and Reporting, LLC, is not rendering accounting, business, financial, investment, legal, tax, or other professional advice or services with this presentation. Further, this presentation is not a substitute for such professional advice or services, nor should it be used as a basis for any decision or action that may affect your business. Before making any decision or taking any action that may affect your business, you should consult a qualified professional advisor. Unclaimed Property Recovery and Reporting, LLC, their affiliates and related entities are not responsible for any loss sustained by any person who relies on this presentation.

3 Objectives Identify Accounts Payable and Related Items that are Potential Unclaimed Property Explain the Holder s Basic Obligations Due diligence and Reporting requirements Pinpoint some of the Risk Factors /Compliance Issues Consider Risk Minimization and Mitigation Practices, Policies and Procedures Note the typical Audit Triggers and Audit Notice Describe Trends and Recent Legislative and Regulatory Changes 3

4 Unclaimed Property Nuances 4 Uniform Act Versions: 1954, 1966, 1981 & 1995 No 2 state laws are exactly the same. No statute of limitations in most state laws Contract auditors some paid by contingent fee State stands in the shoes of the owner Lengthy record retention requirements 55 Reporting jurisdictions throughout the United States and territories. No two jurisdictions have the exactly the same law/requirements Last Known Address v. Contacts/Business Nexus

5 Key Unclaimed Property Terms Intangible personal property: Property held, issued or owing in the ordinary course of business that has remained unclaimed by the apparent owner for a specified period of time after it became payable or distributable is presumed abandoned. Accounting errors are NOT unclaimed property. Holder: An individual or legal entity (public or private) in possession of property belonging to another. Owner: An individual or legal entity (public or private), government or governmental subdivision who has a legal or equitable interest in property. End or As of Date: The date through which a Holder must search its records to determine if it is in possession of unclaimed property. Dormancy Period: The number of years (generally 1,3, or 5) from the date of last contact with the Owner property must be unclaimed before it is considered abandoned. Reporting Deadline: Date report and property due to state. A very few states have different dates to report and deliver property.

6 Unclaimed Property Defined UnclaimedProperty-Anyintangible personal property that is held, issued or owing in the ordinary course of business and has remained unclaimed by the apparent owner for a specified period of time after it became payable or distributable is presumed abandoned. The 1995 Uniform Act defines the term property to mean a fixed and certain interest in intangible property that is held, issued or owed in the course of a holder s business. The 1981 Uniform Act Uniform Act provides that the property must be payable or distributable to be treated as unclaimed property.

7 Unclaimed Property Defined (2) Is there a debt or obligation? ( due and owing ) Has there been owner-generated activity ( unclaimed ) Increase or decrease in amount Written communication with holders Recorded telephone conversation Other relationship / account active (?) Internet account activity (?) Tangible property can be unclaimed property in certain situations as well: Safe deposit box contents Hospital safe keeping items Other custodial property situations: Items left for repair but never picked up

8 Common Unclaimed Property Types A/P (vendor and other uncashed checks or unused payments) Payroll (wages, commissions, expense payments) A/R (credit memos & balances, unapplied cash, rebates) Third Party disbursements Worker s compensation Suspense accounts Self-insured benefit payments Gift cards and certificates Timed deposits Escrow balances IRA, Coverdell and 529 distributions Insurance claim checks/proceeds Annuity distributions Mineral Interest Related Royalties/Proceeds

9 Examples of A/P Related Potential Unclaimed Property Uncashed or Unused: Vendor checks Rebate checks Payroll checks Pay cards Workers compensation checks/distributions Uncashed or Unused: Expense checks Self-insured benefit checks/distributions Settlement checks/distributions Claim checks/distributions Dividend checks 9

10 Examples of A/R Related Potential Unclaimed Property Unused Merchandise Credits Cash on Account Suspense Items Unused Refund Credits Unapplied Cash Customer Deposits Layaway Deposits

11 Which State Has Jurisdiction? Which State s Law Do You Follow? The Rules of UP Jurisdiction (Also called the Priority Rules ): Texas v. New Jersey (US Supreme Court-1965) and later cases: Priority rules: 1. Last known address of the owner/payee/creditor controls 2. When no address sufficient for mailing or owner is unknown, the business state of incorporation controls Uniform Act (adopted by some states): State of incorporation if address of apparent owner is in a foreign country and if holder is incorporated in the US -55 reporting jurisdictions within the US & territories.

12 Which State Law Applies? Example #1 Growingbiz Co. issues a check for $300 to Lotso Stuff, Inc. in payment for supplies. Lotso s address in Growingbiz s records is in Georgia. The headquarters of Growingbiz is in Alabama. Lotso has not cashed the check. Which state s unclaimed property law would apply if the account remains stagnant? Answer: Georgia. This is the classic first rule of Texas v. New Jersey.

13 Which State Law Applies? Example #2 MiCo returns merchandise to YurCo worth $200. Yurco issues a credit to MiCo for $200. MiCo s address in Yurco s records is in Kentucky. Yurco is located in Indiana and incorporated in Delaware. MiCo does not do any further business with Yurco. Which state s unclaimed property law would apply if the credit remains unused? Answer: Kentucky. Again, this is the first rule of Texas v. New Jersey. 13

14 When are a Holder s Obligations Triggered: Determining Item Eligibility Eligibility: When the applicable dormancy period has run, the property is eligible for due diligence plus reporting and remitting. When an item is eligible the holders obligations of statutory due diligence and reporting are triggered. Dormancy Period: States have enacted unclaimed property laws to require that such property be turned over to the state after a statutorily prescribed period of time has elapsed, known as the dormancy or abandonment period. The applicable state statute will determine the following which are important to determining the when : 1.Dormancy period for the property type 2. As of or End date 3.Reporting deadline

15 Examples of Dormancy Periods & Cut-off Dates For Business Associations (non-financial / non-insurance) State Accounts Payable (MS08) Vendor Checks (CK13) Payroll Checks (MS01) Credit Memos (MS09) Dividends (SC01) Annual Reporting Deadline As of / End Date California 3 yrs 3 yrs 1 yr 3 yrs 3 yrs 10/31 (Notice 06/30 Report) Delaware 5 yrs 5 yrs 5 yrs 5 yrs 3 yrs 3/1 12/31 Illinois 5 yrs 5 yrs** 1 yr 5 yrs** 5 yrs 11/1*** 6/30*** Indiana 3 yrs 3 yrs 1 yr 3 yrs 3 yrs 11/1 6/30 Michigan 3 yrs 3 yrs 1 yr# 3 yrs 3 yrs 7/1 3/31 New York 3 yrs 3 yrs 3 yrs 3 yrs 3 yrs 3/10+ 12/31+ Nevada 3 yrs 3 yrs 1 yr 3 yrs 3 yrs 10/31 6/30 Texas 3 yrs 3 yrs 1 yr 3 yrs 3 yrs 7/1 3/1 **May be exempt under certain circumstances. ***Business Association & Life Insurance Companies report 5/1 with 12/31 end date. +NY deadlines vary by industry, i.e., banks- 11/1 w/ 6/1 end date and ins companies- 9/10 w/ 6/30 end date. # Under $50 exempt. ^

16 When Example Lettuce, Olives and Libations, Inc. (LOL) purchased products from Burgers, Fries and Friends, Co. (BFF) and issued/sent BFF a check for $750 in payment which was dated on Feb. 14, The BFF did not cash the check. BFF s address in LOL s records is in Indiana (where CK13 vendor checks a 3-year dormancy period). Would the value of the check be reportable on the 11/1/13 Indiana reporting deadline?

17 When Calculation Example Calculation: IN 2013 End Date = 6/30/2013 LAD or Issue Date = 2/14/2010 Dormancy Time = 3 yrs, 4 mos,16 days NV Dormancy (CK13) = 3 yrs Answer: This value of the check would be due for reporting to NV on the Fall 2013 deadline.

18 ELIGIBILITY FORMULA ED LAD (ID) = DT If DT is greater than DP = Eligible 18

19 A Holder s Basic Compliance Obligations The basic holder compliance obligations* are: Record Review / Internal Due Diligence Due Diligence/Owner Contact Reporting and Remitting Record Retention *All of the above must be done within the time frames and in the formats required by the various applicable state laws. 19

20 Record Review: Minimizing Exposure Record Review Use it to your advantage! This is your opportunity to minimize liability. Common Items to review: Vendor Items Payroll Items Credit Memos / Balances Outstanding check/payment lists (including payments made by 3 rd parties) Industry specific items (checking and savings accounts, insurance claims payments, etc.) Timing: Records should be reviewed at least once a year but preferably every days to stay current Materiality Limit: Set a materiality limit for your review. 20

21 First, determine if the owner is really lost: For A/P items, check vendor master list for a second address or for the address of a parent co or for a related subsidiary. For payroll-related UP, determine if the employee has been terminated or transferred, access retirement info. For customer accounts: Record Review: Procedures Considerations Search internal data pertaining to other types of accounts that the individual or business has with your organization (if found, look for a change of address or activity by the owner on the other account) Review all types of communications sent to or that are possible from the customer, i.e., documented telephone calls or internet (verifiable access) regarding the account, proxy responses, increases or decreases in the account value caused by the owner, etc.

22 Records Review: Procedure Considerations First, determine if the owner is really lost (continued): Use free internet sources to find a new address (i.e. anywho.com, free-people-searchengines.com, switchboard.com) If practical, use a tracing firm or government or commercial database searches (i.e., credit bureaus, Social Security Administration Death Index, etc.) or other services designed to locate the customer/owner or next of kin

23 Records Review: Procedure Considerations A/P Next, review the data for accounting errors A/P: Re-issues without voiding original. Duplicate payments. Incorrect payee. Inter-company payments Periodic/recurring payments (utilities, landlords, etc.) Reconciliation error (i.e., Bank rec has checks w/ sequential numbers outstanding/bad check run). Large dollar checks with familiar payee names. Check represents payment for an invoice for which a credit was issued. EFT s issued simultaneously.

24 Record Review: Procedures Considerations A/R Review the data for accounting errors A/R Validity of the credit: Was the credit applied to an invoice but not deleted from the account record? Was the credit recorded twice? Is the credit really unclaimed property? (i.e. promotional?) Offset: Does the customer have a past due invoice outstanding? Have past invoices been written off to which the credit can apply? Is the customer with the credit also a vendor with a debit balance in AP to which the credit can be applied? 24

25 Records Review: Procedure Considerations Next review the data for accounting errors (continued) : Industry Specific Issues Mistaken postings to account Computer application errors? Misapplied funds Insurance offers settlement (unclaimed property?) Unperfected rebate? (unclaimed property?) Claim disavowed or incomplete? (sitting in agent s drawer?) Other types of items in a pending status

26 Records Review: Procedure Considerations Finally, consider whether the property is exempt from reporting. Business to Business Exemption (tricky-generally, for MS09 credit memos, some CK13 vendor checks) AZ, IL, IN, IA, KS, MD, MA, MI, NC, NY?-administrative, OH, TN, VA, WI (WY - only for gift certificate merchandise credits) Colorado 2% of property remitted or $25 exemption Florida - $10 exemption for credit balances, customer overpayments, security deposits and refunds Kentucky, Michigan, Ohio Wages less than $50 Idaho intangible property valued at $50 or less Gift Certificate / Card Exemptions (tricky)

27 Records Review: Suggested Procedures Summary 1. Review / research outstanding checks/payments on a regular basis (60 90 days) for accounting errors, familiar payee names, offsets, or exemptions. Set a materiality limit Reverse identified accounting errors, make appropriate journal/entries / descriptions 2. Review supplemental information that may lead to the address of a customer, employee or former employee, or vendor 3. Establish contact with the owner through correspondence and telephone calls to resolve outstanding checks or credits, etc. If appropriate, perform database/location searches.

28 Records Review: Suggested Procedure Summary (2) 4. Retain documentation of reversals resulting from research or contact. 5. Maintain and follow written procedures for record review and make them a part of your company s policy or manual. 6. Assign one person at the company who is responsible for escheat compliance, and insert this responsibility in their job description to insure continuity.

29 Compliance Obligation #2: Due Diligence Methods First Class Mail, Certified Mail or Publication Letter Content Timing 60 to 120 days? 6 months? Limitations/Exceptions DE letter requirement only for securities, PA no letter requirement Due Diligence Minimums Special Requirements (i.e., OH-return envelope) Allowable Deductions

30 CA Notice Letter: From CA Holder Handbook UPD/guide_rptg_holderhan dbook.pdf pg 80 30

31 Important Content Elements in a Due Diligence Letter Stated time period within which the owner/heir must contact the holder Form to correct address and to provide instructions to holder Clear direction / instructions to the owner for claiming the property Property identification Statement that the property will be delivered to the state as required by state law if the owner / heir does not act and do so timely 31

32 Compliance Obligation #3: Annual Reporting & Remittance Type of Report Diskette, CD, On-line? Minimum thresholds, on-line (i.e., AL and IN now mandate by law electronic reporting and remitting. ID mandates electronic reporting if reporting over 10 items. MT by interpretation now mandates reporting via their website portal.) Report Format NAUPA II format? / Holder #? Negative Reporting About 30 states/some on-line Michigan Attestation Report & Remittance Delivery On time, verifiable For most industries and property types the reporting deadline is on or near 11/1 of each year (Fall cycle). Others 2/15 5/1 (Spring cycle), Texas & Michigan 7/1 (Summer Cycle) Filing Extensions Reason? Timing? Estimated liability? State form?

33 Reporting Date Breakdown: Non-Insurance Corporations

34 Example: UP Report Cover Sheet - New York Verification and Checklist

35 Reporting Nuances California Dual Reporting Aggregate Reporting a good idea? Michigan and Texas Summer Reporting Deadline and March as of dates (Summer cycle) New York certified mailing AND for some industries a publication requirement as well NAUPA property and relationship code use varies among states States requirements for electronic / on-line reporting vary

36 Remitting Unclaimed Property Some states now require remitting via electronic means: EFT/ ACH Alabama and Indiana require by law that the remittance be delivered electronically. If checks are permitted, must insure that the payable to is correct: Examples: Illinois: Illinois State Treasurer Ohio: Ohio Department of Commerce Minnesota: Minnesota Department of Commerce Wisconsin: Wisconsin State Treasury 36

37 Compliance Obligation: Reporting Red Flags! Tips - Preventing Reporting Red Flags by: Use the state prescribed cover sheets and/or holder numbers when filing reports Make sure your reports/cover sheets are completed and signed (and notarized if required) Insure that the report reflects the same dollar amount that is reflected by your remittance Request filing extensions within the states prescribed periods prior to the filing deadline (you may have to request in writing and/or on a state form) File all property types: securities and general ledgerrelated and filing them accurately (not disproportionately)

38 Compliance Obligation #4: Record Retention 1. Retention Time Period 1995 Uniform Act (Section 21) a holder required to file a report must maintain the records containing the information required to be included in the report for 10 years after the report is filed. (Ten (10) years from date property was first reportable.) Consider state audit reachback periods! 2. Records to Retain 1995 Uniform Act (Section 21) is silent on this issue. Practical Considerations: Audit Protection Substantiation for reversals - accounting and data errors Evidence of reporting and timely reporting Evidence of due diligence (including certified mailing if it is required.)

39 Risk Management: Policies and Procedures Outline Your Policies and Procedures Should Include: Periodic Generation of Reports of Outstanding Items Research Methods to Identify Potentially Unclaimed Items A Description of the Measures for Resolving Items Notification of Owners/Vendors re Outstanding Items (Sample Letter in Procedures?) The Procedure for Reporting & Remitting property to the Appropriate State(s) and for Recording same Record Maintenance Standards and Steps/Procedures A Method for Maintaining and Updating Compliance Requirements A Time Table for All of the Above Appropriate Separation of Tasks and Task Assignments

40 Risk Management: Management Support & Staff Assignment Management Buy-In Task Assignment: Centralized or Decentralized Some benefits of centralization Uniformity of procedures Submitting consolidated returns One voice to state UP offices Greater efficiency in customer research and due diligence Challenges of a centralized process: Ensuring that you have full support of the various internal business partners Keeping track of new product offerings Tracking regulatory changes and reporting requirements for a variety of product types

41 Risk Management: Audits TRIGGERS A few examples: Holder has presence in or is incorporated in state but no reports filed Holder is big enough to warrant scrutiny by state of incorporation Amounts reported appear too small for size of the holder Unlawful deductions or large aggregate amounts in previously filed reports Gaps in reporting history No reach back on initial reporting Inadequate due diligence (e.g., high rate of claims from state)

42 Risk Management: More Audit Triggers History of mergers, acquisitions, reorganizations, liquidations, dissolutions, incorporations A specific period of time has passed since a previous audit High volume of financial transactions (e.g., Retailers or Distributors) Unique property types (e.g., IRAs, Gift Cards) Reporting some property types but not all that are common to your Industry Holder name recognition

43 Audits: Chronological Components 1. Notice 2. Schedule 3. Document Requests 4. Sampling and Extrapolation 5. Initial Findings Report 6. Negotiation 7. Final Report 8. Appeal?

44 The Audit Notice: The States First Move A Holder s Preliminary Questions 1. Who is performing the audit? (State or third party auditors?) 2. Which states are involved? State of incorporation? 3. What is the time period covered ( scope ) of the audit? REACH BACK PERIOD? 4. What audit procedures will be used? (What extrapolation procedures will be used when records are incomplete or nonexistent?) 5. What are the auditors schedules and site requirements? 6. Will the state(s) or their agent sign a confidentiality and scope limitation agreement? 7. Should legal counsel and outside expertise be obtained to handle audit issues in a privileged context?

45 Audits: Current Trends Extended reach back periods for non-filers Sampling and extrapolations Drawn-out audits State audit costs charged to the holder Third-party administrators

46 The Risk: Penalties and Interest Under most state UP laws, penalties and/or interest can be imposed for failure to perform any duties required by law, including failing to report and remit or to do so timely. (1981 Act includes criminal AND civil penalties) 1995 Act Penalties: 1. Interest : 2% above the annual Treasury bill discount rate in effect on the date the property should have been paid or delivered 2. Not Willful Failure: $200 for each day the report, payment, or delivery is withheld, or the duty is not performed, up to $5, Willful Failure: $1,000 per day from the report due date up to $25,000, + 25% of the property value that should have been reported 4. Fraud: $1,000 per day from the date a report due date up to $25,000, + 25% of the property value that should have been but was not reported. (#1 plus #2 or #3 or #4 can be applied under 1995 Act)

47 Latest Trends and Developments Recent Trends Recently Enacted Legislation Significant Pending Legislation

48 Recent Trends Industry Targeted Audits: Life Insurance, Securities Transfer Agents Broker Dealers New or Enhanced Voluntary Disclosure Programs Delaware Secretary of State Program Minnesota Department of Commerce Program Changing Eligibility trigger rules/definitions Delaware s and other states change in the lost interpretation

49 Recently Enacted Legislation Delaware SB 258 and HB 2 creates a new Voluntary Disclosure Program (VDA) under the Secretary of State that has shorter look back periods to 1996 or Sunsets 6/30/2015. Idaho SB 1365 exempts the unclaimed property audit methodology and selection criteria from disclosure under the state s Public Records Act Michigan HB 4563 creates an exemption from unclaimed property requirements for credit balances, overpayments, deposits, refunds, discounts, rebates, credit memos or unidentified remittances created on or after April 1, 2009 and issued, held, due or owing in any transactions between 2 or more associations. Exemption does not apply to outstanding checks. North Carolina HB 462 prohibits Treasurer from contracting for UP auditors to perform audits on a contingency fee basis except for certain audits of life insurance companies. North Carolina SB 810 decreases record retention period from 10 to 5 years after the holder files a report. North Dakota SB 2058 Prohibits the UP administrator from contracting for audits in ND unless there is reasonable cause to believe that the business has failed to comply with the ND UP statute. 49

50 Recently Enacted Legislation Alabama HB 112: Among the many changes made are: Requires reports and remittances to be delivered and requires separate reports for tangible and intangible property. Allows the state to establish aggregate reporting threshold by (current = $50 aggregate). Changes the due diligence time frame to not less than 60 days before filing the report and permits the state to increase the due diligence minimum (now $50) by rule Establishes that property reported early will be deemed abandoned property and handled in the same manner as all other abandoned property. Indiana SB 222: This bill makes many changes including: Requires reports and remittances to be delivered electronically. Authorizes the attorney general to deduct from the proceeds paid to the owner, the costs of selling property (including tangible property and securities) or costs of identifying or recovering property (including the costs of examination or costs incurred in connection with an interstate agreement). Deduct audit costs/contingent fees from owner proceeds?

51 Recently Enacted Legislation Alabama HB requires insurers to perform the death master file comparisons every 3 years plus other provisions including remitting unclaimed benefits/retained assets with interest to the State Treasurer. Effective 1/1/14 Kentucky HB requires life insurers to perform death master file comparisons quarterly on in-force policies & retained asset accounts and if benefits due, locate &notify beneficiaries. Effective 1/1/13 Maryland SB 77 life insurers must perform death master file comparisons semi-annually on in-force policies & retained asset accounts and if benefits due, locate & notify beneficiaries. Effective 10/1/13. New York AB 9845 requires life insurers to perform quarterly death master file matches against in-force life insurance policies and retained asset accounts and to locate and notify beneficiaries. Requires the Superintendent of Insurance to create a Lost Policy Finder program.

52 Recently Enacted Legislation Montana SB 34 - requires life insurers to perform death master file comparisons semi-annually on in-force policies, annuity contracts, and retained asset accounts & if benefits due, locate and notify beneficiaries. North Dakota HB requires life insurers to perform death master file comparisons befores 11/1/2014 and then, semiannually on in-force policies, and retained asset accounts & if benefits due, locate and notify beneficiaries. Reduces the dormancy period from 3 years to 1 year for funds held or owing under a life or endowment insurance policy or annuity thar has matured or terminated. I New Mexico SB 312 requires that at least twice a year, a life insurer shall crosscheck its insureds' in-force life insurance policies and retained-asset accounts against a death master file & if benefits due, locate and notify beneficiaries. Vermont HB 95 - requires life insurers to perform death master file comparisons semi-annually on in-force policies, annuity contracts, and retained asset accounts and if benefits due, locate & notify beneficiaries.

53 Significant Pending Legislation California AB 212, as amended; Reduces the aggregate limit to $25 from $50 beginning 1/1/2014. Illinois SB 1988: Reduces the dormancy period to $5 from $25. Michigan HB 4289: Sets requirements regarding audits including the standards to be used, the information that must be provided to the holder and sets a standard for when estimation can and cannot be used. Requires any UP examination to be conducted using generally accepted auditing standards to the extend applicable and that the UP administrator or his her agents provide to those who are audited a completed copy of the audit report. Michigan HB 4703: Creates an step by step audit appeals process. Requires that when under-reporting discovered in an audit, the UP administrator must deliver to the holder a statement of findings and request for payment. If after the administrative appeal process the holder appeals the administrative decision to circuit court, the court's review is limited to whether the Treasurer's determination was supported by substantial evidence on the record.

54 Significant Pending Legislation (cont.) California AB Restricts UP claims so that only a person who claims to have been an owner, as defined, may file a claim with the Controller. The bill would revise the definition of owner to also include the estate representative and guardian or conservator, and remove the legal rep of the person who had the legal right to the property prior to its escheat. Massachusetts HB 20 - requires life insurers to perform death master file comparisons semi-annually on in-force policies and retained asset accounts & if benefits due, locate and notify beneficiaries. Rhode Island HB 5452 requires life insurers to perform death master file comparison semi-annually on in-force policies and retained asset accounts & if benefits due, locate and notify beneficiaries

55 THE UUPA REWRITE AND THE ABA MODEL ACT CREATION Uniform Unclaimed Property Act (UUPA) History Uniform Law Commission Schedule (ULC) for UUPA Revisions 1954, 1966, 1981 and the 1995 Acts 1995 Act: Alabama, Arizona, Arkansas, Hawaii, Indiana, Kansas, Louisiana, Maine, Michigan, Montana, New Mexico, North Carolina, West Virginia, Vermont, Virgin Islands April Stakeholders Meeting & July ULC Commission Meeting American Bar Association Model Act First Attempt / Approach Section by Section A Call to Action?

56 POTENTIAL UUPA REWRITE AND ABA MODEL ACT ISSUES Rules of Custody / Foreign Property/ Domicile Address Definition Eligibility Issues: Contact Reporting Issues: Deadlines, Codes, Aggregate and Electronic Reporting/Remitting Due Diligence Issues: Address Sufficiency, Minimums, Electronic Contact Record Retention / Audit Reach Back Audit Issues: Estimation and Administrative Appeals Process Statute of Limitations Exemptions: B2B and DeMinimus Newer products: HSAs, FSAs, ESAs Timing of states sale of securities

57 Resources 1. Unclaimed Property Professionals Organization (UPPO) (Annual Conference : March th, 2014 Dallas, Texas) 2. National Association of Unclaimed Property Administrators (NAUPA) 3. NAUPA II Standard Reporting Format: (click on new reporting standard ) Uniform Unclaimed Property Act y/uupa95.pdf

58 Your Presenter Today: Karen Anderson, Sr. Vice President