If it’s Tax Season it also means PA Escheat Season
If it’s Tax Season it also means PA Escheat Season!
With the April 18th reporting deadlines just on the horizon, many institutions are in process of scrubbing their dormant accounts for potential escheat processing. If you fail to report timely, the penalty is 12% interest! So start with the Department of Treasury’s “Unclaimed Property Annual Reporting” (2017 Report Year) found at https://www.patreasury.gov/pdf/unclaimed-property/Holder-Reporting-Book.pdf .
PA’s escheat period for most property is 3 years, meaning the Bank has had no contact with the account owner and no interest has been expressed by the owner during that period. The exceptions are for Money Orders (7 years) and Travelers Checks (15 years). A complete Dormancy Matrix is located at https://www.patreasury.gov/pdf/unclaimed-property/Dormancy-Matrix.pdf
Due Diligence – Effective September 10, 2016, several new requirements were required. The first of these is “Due Diligence.” The holder must now send notice to the property owner not more than 120 days nor less than 60 days prior to the reporting date if the property has a value of $50 or more. The notice should include the property description, ownership, and value plus the Bank’s contact information for preventing escheatment. If the property is claimed, then escheatment is prevented.
Reporting Methods – If the institution is reporting less than 10 properties, use the written form from the Dept of Treasury’s website. If more than 10, electronic reporting via email, CD-ROM, or through the Holder Reporting, Step 2 process on the Department’s website is required.
Negative Report – If you have no unclaimed property to report, then use the one-page voluntary negative report to let Treasury know. https://www.patreasury.gov/pdf/unclaimed-property/Voluntary-Disclosure-Agreement.pdf It’s not mandatory but since you’ve searched your records, you should report your compliance status.
Remittance – Escheated funds can be remitted via check, wire transfer, or ACH.
Have more questions? Consult the FAQ near the end of the Holder Reporting Book or email Evelyn Dehmey at edehmey@fosaudit.com.
Evelyn I. Dehmey | If it’s Tax Season it also means PA Escheat Season