Don’t Forget The Spring Filings

Week of March 30, 2012

Blog Post by Kathleen Moyer, Managing Partner – Compliance Services

It’s important to remember that the states have “Fall” and “Spring” unclaimed property reporting requirements.   Although most corporations focus on the Fall unclaimed property reporting cycle, it’s important to remember that nine states are Spring reporting states.  Michigan, New York, Illinois, Pennsylvania, Delaware, Tennessee, Connecticut, Florida, and Vermont filing deadlines range from March 10 to July 1.  In addition, California, Hawaii, and Maine have “special reports” that are also due in the Spring of each year. 

We’re sometimes asked by corporations whether they can report all their unclaimed property to the states in the Fall and ignore the Spring filing deadlines all together.  We would not recommend this.  As inconvenient as it may be to have Fall and Spring reporting cycles, it is important that all the states’ required due diligence be performed before turning the funds over to the states.  Reporting the funds early in the previous Fall cycle, would cause the funds to be reported before the states’ Spring cut-off deadline of December 31 and before due diligence can be performed.  Reporting the funds late in the current Fall cycle could result in the assessment of interest due to late reporting.  It’s not worth the risk.  Our advice is to comply with the state unclaimed property laws.  First, by performing your due diligence and secondly, by reporting according to the states’ reporting schedule.