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Compliance Update Month-by-Month Compliance Obligations. Mark Vogel – Chesapeake Systems. Unclaimed property is NOT just a Fall and Spring Process Don’t let compliance obligations slip through the cracks Employee turnover can create non-compliance and audit risk. - PowerPoint PPT Presentation
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Solutions Summit 2014
Compliance Update Month-by-Month
Compliance Obligations
Mark Vogel – Chesapeake Systems
Chesapeake System Solutions, Inc. • Proprietary and Confidential
• Unclaimed property is NOT just a Fall and Spring Process
• Don’t let compliance obligations slip through the cracks
• Employee turnover can create non-compliance and audit risk
Chesapeake System Solutions, Inc. • Proprietary and Confidential
JULY (state reports due for MI & TX)
• Generate and review Michigan and Texas reports• Start compiling final detail for Fall/November
reports from all departments. This covers all outstanding transactions originating June 30, 20XX and prior• Commence the preparation/mailing of all due
diligence letters to potential owners, or other necessary notifications, based on the various State statutes
Chesapeake System Solutions, Inc. • Proprietary and Confidential
AUGUST (state reports due for GU & PR)
• Generate and review Preliminary Reports to Guam and Puerto Rico • Due diligence/search letters to be mail out to owners in
early August (at the latest)• Begin to track & update owners affirmative due
diligence responses• Get approval to attend Chesapeake’s Annual UPCS
User’s Conference
Chesapeake System Solutions, Inc. • Proprietary and Confidential
SEPTEMBER (State reports due for MN & NY)
• Generate and review Minnesota and New York reports• Set cut off date for responses resulting from due
diligence• Final update of all owners having affirmative responses
to due diligence mailing• Affirmative responses after September may be told to
contact appropriate State to claim funds• Upon proof, begin to generate payment checks to
owners of affirmative response property
Chesapeake System Solutions, Inc. • Proprietary and Confidential
OCTOBER (Big month. State reports due for many states)
• Generate unclaimed property reports in preview mode for review and accuracy (early Oct.)• Upon review, generate reports for signature of Company
Officer• Submit/mail (Certified/Overnight/First Class) signed unclaimed
property reports to appropriate States (mid-Oct.)• Track receipt & acceptance of all reports• Do any State reporting forms require notarization?• Ensure that applicable State reports and remittance are
received by these State’s no later than October 31st. State may allow report to be “postmarked” October 31st.
Chesapeake System Solutions, Inc. • Proprietary and Confidential
NOVEMBER (Big month. State reports due for many states)
• Ensure that applicable State reports and remittance are received by these State’s no later than November 1st. State may allow report to be “postmarked” November 1st.• Finalize affirmative responses from due diligence
mailing and issue payment checks• Reconcile all items reported to States or removed during
Fall reporting cycle
Chesapeake System Solutions, Inc. • Proprietary and Confidential
DECEMBER (state reports due for CA,DE, GU, PR)
• Generate and mail Final unclaimed property reports to Guam and Puerto Rico by December 10• LI’s Generate and mail Final unclaimed property reports to
California by December 14• LI’s Generate and mail Final unclaimed property reports to
Delaware by December 20• Consider performing search for funds owed to your company
held by States (missingmoney.com)• Send thank you email to all appropriate personnel that
assisted with Fall reporting!• If done by yourself, take week off!!
Chesapeake System Solutions, Inc. • Proprietary and Confidential
JANUARY (no state reports due)
• Start compiling final detail for Spring reports from all departments. This covers all outstanding transactions originating December 31, 20XX and prior• Commence the preparation/mailing of all due diligence
letters to potential owners, or other necessary notifications, based on the various State statutes
Chesapeake System Solutions, Inc. • Proprietary and Confidential
FEBRUARY (no state reports due)
• All required due diligence letters must be mailed out to property owners (early Feb.)• Begin tracking affirmative responses to due diligence mailings• Generate and review Delaware unclaimed property report• Cut off for owner response to due diligence mailings• Upon proof, begin to generate payment checks to owners of
affirmative response property• Do any State reporting forms require notarization?• Sign (by Company Officer) and mail DE report and remittance
to State by March 1st
Chesapeake System Solutions, Inc. • Proprietary and Confidential
MARCH (state reports due for DE, NY, CT)
• Delaware report/remittance due March 1• Generate and review New York applicable unclaimed property reports• Sign (Company Officer) and submit NY report and remittance to State
by March 10• Generate and review Connecticut reports• Sign (Company Officer) and submit CT report and remittance to State
by March 31• Attend annual Unclaimed Property Professional’s Organization
(“UPPO”) Conference• Conference for all Holders• Wealth of information and industry contacts
Chesapeake System Solutions, Inc. • Proprietary and Confidential
APRIL (state reports due for numerous states)
• Generate and review Pennsylvania reports• Sign (Company Officer) and submit PA report and
remittance to State by April 15• Generate and review Florida, Illinois, Tennessee &
Vermont reports• Sign (Company Officer) and submit FL report and
remittance to State no later than April 30th. State may allow report to be “postmarked” April 30th.
Chesapeake System Solutions, Inc. • Proprietary and Confidential
MAY (Big month. state reports due for numerous states)
• Sign (Company Officer) and submit IL, TN & VT reports and remittance to States no later than May 1st. State may allow report to be “postmarked” May 1st.• Finalize affirmative responses from due diligence
mailing and issue payment checks• Reconcile all items reported to States or removed during
Spring reporting cycle
Chesapeake System Solutions, Inc. • Proprietary and Confidential
JUNE (state reports due for 1 state – CA)
• Should actually be a pretty slow month!• Generate and review Final State Report for California• Send thank you email to all appropriate personnel that
assisted with Spring reporting!• If done by yourself, take week off!!• Consider performing internal unclaimed property
policies & procedures and past State reports review• Consider performing another search for funds owed to
your company held by States (missingmoney.com)