COVID-19 Unclaimed Property Info

Unclaimed Property Tax | Filing Extensions by State

Effective September 15, 2020, we have paused updates to the tracking charts that we have maintained since March, as COVID-related legislation and updates have slowed significantly. We will continue to monitor state legislation and updates and will update our COVID-19 resources as necessary and will post blogs to keep you informed.

Due to the present circumstances and continued uncertainty surrounding the COVID-19 outbreak in the US, DMA is closely monitoring the unclaimed property compliance requirements for annual filings and due diligence requirements.

Click here to learn more about how DMA is supporting our clients during the COVID-19 pandemic.

Below is a chart summarizing current information provided by the state agencies with deadlines through July 2020, noting any extension availability and/or process changes. DMA will continue to monitor the current situation and provide our valued clients with weekly updates. If you have any questions or concerns, please do not hesitate to reach out to our Unclaimed Property team as we are here to assist.

UPCOMING STATE REPORTING REQUIREMENTS

STATE	FILING DEADLINE	FILING METHOD	SIGNED PAPER FORM REQUIRED	NOTARIZED REQUIRED	EFT PAYMENT OPTIONS	DETAILS	LAST UPDATED
CA 2019 Final Report	6/14/20	CD	Yes	No	ACH Debit, ACH Credit	Per Betty T. Yee, California State Controller, Unclaimed Property Division: At this time, we are accepting electronic signatures and report “packages” (NAUPA file, UFS-1 with electronic signature, and 14F) via email to UCPReporting@sco.ca.gov. You will need to contact the EFT Desk at UPDSCOEFT@sco.ca.gov for questions regarding electronic funds transfer. Notice to Holders Final Remit Report and Remittance Due Date Postponed - Due to the COVID-19 pandemic Controller Yee has postponed the final unclaimed property Remit Report and remittance due date, as authorized under Code of Civil Procedure section 1532. This extension results in the following: The June 1 - 15 period for holders to submit their reports and remittances for properties reported on 2019 Notice Reports is extended from June 1, 2020, to August 15, 2020. Holders or agents of holders who are able to submit their Remit Reports and remittances during the original reporting period are encouraged to do so. The Unclaimed Property Division continues to process unclaimed property reports and claims. If you have any questions, contact the Outreach and Compliance Unit at updholderoutreach@sco.ca.gov.	6/4/20
MI	7/1/20	Online	No	No	ACH Debit at time of filing	Per the state statute, the state administrator may postpone the date to file a report, on written request by any person required to file a report under this section. The administrator may extend the filing date for up to 60 days after the deadline if an estimated payment is paid on or before the deadline for the applicable period. Remittance of an estimated payment without a report on or before the deadline shall be considered a request for extension. A request for extension of time to file the report is not a request for an extension of time to remit payments.	4/7/20
TX	7/1/20	Online	Yes*	No	ACH Debit, ACH Credit	*A remitance coupon will be presented at time reported is submitted online and will need to be signed and included if paying by check. Texas Comptroller of Public Accounts, Unclaimed Property Division: If you believe that you will not be able to provide effective notice to owners before the July 1, 2020, due date, request a waiver of penalty and/or interest for the properties due for your 2020 report. The request should include the following information: •Business name •Federal Employer Identification Number (FEIN) •Reason for the request •Date you plan to submit your report and payment •Contact information including name, email address and phone number To submit your request or ask any questions on the due diligence suspension, please contact the Holder Education and Reporting section at up.holder@cpa.texas.gov.	5/6/20

OWNER NOTIFICATION REQUIREMENTS

STATE	LAST DAY TO MAIL LETTERS	STATE MIN. THRESHOLD	MAILING METHOD	STATE PROCESS UPDATES	LAST UPDATED
CA 2020 Prelim Report	4/30/20	$50	USPS - First Class Mail	No known updates or process changes for Formal Due Diligence requirements as of 3/31/20	4/7/20
MI	5/1/20	$50	USPS - First Class Mail	No known updates or process changes for Formal Due Diligence requirements as of 3/31/20	4/7/20
TX	5/1/20	$250	USPS - First Class Mail	Texas Comptroller of Public Accounts, Unclaimed Property Division: Section 74.1011 of Texas Property Code requires holders to provide the due process notice to owners that their property may be reported to the Texas Comptroller of Public Accounts as unclaimed property. For the 2020 report year, exceptions are being allowed in cases where holders are unable to complete the notification by mail and by the deadline. Updates to the requirements of Section 74.1011 for the 2020 report year are: •Holders having trouble meeting due diligence requirements due to COVID-19 are still required to provide effective notice to owners prior to reporting the property but now have additional time to send notice to owners. •Holders may now also use alternative means including electronic mail, telephone or other reasonable means to provide the notice to owners. •Holders should be aware that this suspension does not waive the notice requirement before reporting unclaimed property. •Holders must allow owners a reasonable amount of time to respond to the notification prior to reporting the property.	5/6/20

DuCharme, McMillen & Associates, Inc. (“DMA”) makes no warranties, promises and/or representations of any kind, expressed or implied, as to the reliability, accuracy, timeliness or completeness of this information, nor to the suitability or otherwise of the information to your particular circumstances, and all information is provided on "as is" basis. The information provided is fluid and constantly changing and DMA undertakes no responsibility to update the information as it changes. The information is provided for informational purposes only, is not intended to be relied upon by you or any other person for any purpose whatsoever, and shall not be considered tax, legal or other advice. The user of the information must rely on its own professional advisors.

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