UPPO Regional Breakout“Poll the States”

Presented by:Mike Ryan – Eastern Region Vice President

Troy Wangen – Outgoing Midwestern Region Vice President

Heather Steffans – Incoming Midwestern Region Vice President

Chris Jensen – Outgoing Southern Region Vice President

Michele Graf – Incoming Southern Region Vice President

Scott Pettinato – Outgoing Western Region Vice President

Lisa Linden – Incoming Western Region Vice President

UPPO Presentation Disclaimer

Use of the Unclaimed Property Professionals Organization, Inc., (UPPO) name of copyrighted

materials in this presentation does not constitute an endorsement by UPPO of a member, vendor, product or service. The content represents the

opinion of the author and not necessarily those of UPPO. This information is not intended as legal

advice and should not be used to replace the advice of legal counsel.

UPPO Antitrust StatementUPPO has a policy of strict compliance with federal antitrust laws.

UPPO members and/or meeting attendees cannot come to understandings, make agreements, or otherwise concur on positions or activities that in any way tend to raise, lower or stabilize prices or fees. Members and/or attendees can discuss pricing models,

methods, systems, and applications, as well as certain cost matters that do not lead to an agreement or consensus on prices or fees to be charged. However, there can be no

discussion as to what constitutes a reasonable, fair or appropriate price or fee to charge for any service or product.

Information may be presented with regard to historical pricing activities so long as such information is general in nature and does not include data on current prices or fees being

charged in any trade area. Any discussion of current or future prices, fees, discounting, and other terms and conditions of sale, which may lead to an agreement or consensus on prices

or fees to be charged, is strictly prohibited.

Any questions about UPPO’s antitrust policy should be directed to UPPO’s Executive Director.

Today’s Agenda

Over the past few weeks, the Regional Vice Presidents polled their respective

jurisdictions to answer questions YOU asked. Today, we will provide the states’ answers and provide any additional clarification.

Today’s Agenda

• Basic Reporting Questions

• Due Diligence Questions

• Legislation & Statute Questions

• Audit Questions

• Asset Recovery Questions

• General Questions

States that Responded

CaliforniaDistrict of Columbia

FloridaLouisianaMissouriNew YorkOregon

PennsylvaniaWashingtonWisconsin

To ask the other states…

An additional holder benefit is the State

Administrators Outreach Forum. Send

questions to toni@uppo.org and she will

review and post appropriate questions to

the states.

Basic Reporting Questions

Question #1

Does your State offer reciprocal reporting and do you recommend it for Holders?

Any advice for Holders who do reciprocal reporting?

Question #2

What is the most common reporting error you see Holders make?

Question #3

A Holder’s software doesn’t interface directly with each state which requires us to send CDs or flash drives with the state reports. After state reports are received, how does your state ensure that the Holder’s data is

protected?

Question #4

What are some recommendations for making the unclaimed property process more

efficient beyond tracking via a third party software?

Question #5

Does your state allow for report extensions and what is required to request an

extension?

Question #6

Many times there is a delay between the date a report is submitted and the date it is uploaded

or otherwise entered into the state system. Upon occasion, the Holder will receive notice

several weeks after submission that a report on a CD can’t be opened, or the online report is

missing information. If a report was submitted timely, in good faith, but there is a problem with it, will the state subject the Holder to interest or

penalties if the report has to be submitted?

Question #7

Is it a requirement for all unclaimed property to be filed regardless of the dollar amount of the property? Do any states have aggregate

amounts where filing is not required for certain amounts?

Question #8

In the best interest of an accountholder, does your state hold liquid assets, in kind, instead of liquidating it? If not, please provide the

reason.

Due Diligence Questions

Question #9During the due diligence process, the Holder will mail out several letters relating to death claim benefits. In many instances the Holder receives a response back to the letters acknowledging the owner will be required to

provide specific documentation in order for the claim to be paid. The Holder’s claims examiners send a letter to the requestor stating what type of

documentation needs to be provided in order to pay the claim. There have been several instances whereby the Holder’s claims examiners send a second

and third request for the information. Sometimes a response is never received, yet because the Holder received an initial response to our due

diligence letter the last contact date is updated to reflect the most recent contact. This change in the last contact date starts the clock over. The Holder’s claims examiners end up getting frustrated because this entire

process will start again and due diligence letters will be mailed again in the future most likely ending with the same result. Is the Holder required to update the last contact date to reflect a current date or can we remit the

funds to the appropriate state when they become due that year?

Question #10

When a beneficiary comes to the state to claim funds, what is the process that the states go through to verify the person is

entitled to the funds? The insurance company requires paperwork and death

certificates, etc. Do the states require the same?

Question #11

What should Holders do if funds are not reported to the states because they received

a due diligence letter back but it was later determined the person did not supply the necessary information to finish the claim?

What should the Holder provide to show the reason the funds would not be past due?

Question #12

What is your advice for sending due diligence letters to seasonal hires and interns who are

not required to provide the Holder with a permanent address, email or phone

number? Typically these individuals travel back and forth or work for a short period of time and will use the company’s address as

their own.

Question #13

Do you see mistakes Holder may be making regarding due diligence? Do you have a due

diligence template on your website?

Legislation & Statute Questions

Question #14

Does your state have any recent changes (e.g., dormancy periods, due diligence, B2B, gift cards, etc.) or new property type codes?

Question #15

Is your state entertaining implementing the Revised Uniform Unclaimed Property Act?

For all RUUPA related alerts, check out UPPO’s new Advocacy web page:

http://www.uppo.org/page/Advocacy17

Question #16

Does your state have a formal or informal VDA? If yes, what is the look back period?

Audit Questions

Question #17

How are the state administrators governing the contingent fee auditors? Based on the recent cases and legislative changes, would there be more stringent oversight or would there be a shift from third party auditors to

more in-house/desk audits?

Question #18

Do you use a third party audit firm? If so, who?

Asset Recovery Questions

Question #19

What are some tips for developing a sustainable process to search for unclaimed

funds that belong to a company vs. an individual?

General Questions

Question #20

If you have one piece of advice for a first-time Holder and/or filer, what would it be?

Question #21

If a Holder reports foreign addressed property to its state of incorporation – what are the state’s next steps with the remitted

funds?

Question #22

A minority of states exempt transactions between businesses from the statutory definition of unclaimed property (B2B

exemption). Other than revenue generation, what justification is there to claim funds that

are purportedly owed to another business organization?

Question #23

With look back periods being shortened, what are the chances a Holder can get a

refund on estimated amounts paid for the reduced period?

Question #24

Do the states issue 1099s for the money paid out on death benefits?

Question #25

How do the tax laws apply to unclaimed property?

Q & A

Check out the Jurisdictional Guide for

specific state questions or links to the

state websites for more information. A

great Member benefit!

THANK YOU FOR ATTENDING THE 2016 UPPO ANNUAL

CONFERENCE!

SAFE TRAVELS HOME AND SEE YOU NEXT YEAR IN TAMPA, FL!