Unclaimed Property Reporting and Due Diligence
“Unclaimed property (sometimes referred to as abandoned) refers to accounts in financial institutions and companies that have had no activity generated or contact with the owner for one year or a longer period. Common forms of unclaimed property include savings or checking accounts, stocks, uncashed dividends or payroll checks, refunds, traveler's checks, trust distributions, unredeemed money orders or gift certificates (in some states), insurance payments or refunds and life insurance policies, annuities, certificates of deposit, customer overpayments, utility security deposits, mineral royalty payments, and contents of safe deposit boxes.” (NAUPA- National Association of Unclaimed Property Administrators)
The University of Pennsylvania holds unclaimed property until the dormancy period established by the owner’s state of residence has run out. Once the dormancy period has expired, the University must report it to the appropriate state. Due diligence must be performed to attempt to reunite the property with the owner prior to reporting.
Unclaimed property is regulated on a state level. Because of this, there is no uniform standard to follow with regard to dormancy periods and reporting requirements. There are currently five types of property that the University reports to each state.
- Accounts Payable Checks
- Imprest Account Checks
- Payroll Checks
- Accounts Receivable Credits
- Debit Balance Card Balances
Each School and Center is to complete due diligence on any of the property types listed above that they hold. They are also expected to report to Tax and International Operations the results of their due diligence on a quarterly basis.
A spreadsheet document and process has been developed to facilitate and document the review process. It will also meet the SAS 112 formalized control requirements including certification which evidences completion and review of the procedures and results. The Comptroller's Office will collect these documents to facilitate audits by external parties and provide additional guidance as necessary.