Preparing for the upcoming unclaimed property spring 2025 compliance season

The new year is here, and now is time to prepare for spring and summer unclaimed property compliance as the March 1 through April 30 deadlines for 2025 are quickly approaching. For most corporations, the spring reporting states include Connecticut, Delaware, Florida, Guam (Jan. 31, 2025), Illinois, New York, Pennsylvania and Vermont (note that these deadlines may differ for insurance and financial services industries). Whether you have just taken on unclaimed property compliance or have been doing it for years, here are five things to keep in mind when getting ready for the spring 2024 unclaimed property compliance season:

1. Review all sources of potential unclaimed property.

• Common property liability types: Includes, but not limited to, aged accounts receivable net credit balances, stale dated/uncashed accounts payable and payroll disbursements.
• Industry specific liability types: Industry specific properties can include, but is not limited to, mineral interests and royalty payments, equity positions, bank account balances, life insurance policy proceeds, uncashed money orders and utility deposits.
• Hidden liability types: This may include unreported liabilities acquired from a merger, liabilities from third party administered plans for which the third party does not report unclaimed property on a holder’s behalf, or even marketing efforts that result in entitlements that have not been satisfied.
• Tangible property types: Most commonly this includes, but is not limited to, abandoned safe deposit boxes.

1. Due diligence. If you have not done so yet, the window of time to send your statutorily required due diligence notification letters to the owners of unclaimed property held by your company is quickly closing, or depending on the state, may have already closed. In addition to the specific timing requirements on when the letters must be sent, make certain your team is following newly adopted legislative requirements in the various states impacting the dollar thresholds and content of these letters.
2. Legislative changes. Many states have enacted new laws impacting unclaimed property. For example, Connecticut and Florida have enacted new requirements regarding due diligence requirements that companies must follow when sending outreach letters to apparent owners. Now is the time to confirm that your team understands how these, and other state changes, may impact the spring 2025 unclaimed property reporting process.