COVID-19 Unclaimed Property Jurisdictional Updates
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Alaska
• Due Diligence: Alaska will work with holders on all due diligence matters, including extensions.
• Foreign Owner Due Diligence: Due to the U.S. Postal Service temporarily suspending service to a long list of countries, an email notification will suffice. If email is not available, file an extension and wait until due diligence can be completed.
• Safe Deposit Boxes: Alaska will gladly extend the filing and remittance dates for safe deposit property.
https://treasury.dor.alaska.gov/05/04/20 5:19 PM
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California
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 of June 1 – 15, 2020 are encouraged to do so, and the Unclaimed Property Division is continuing to process unclaimed property reports and claims.

California has also extended its deadline for life insurance companies to file unclaimed property holder notice reports until June 30, 2020.
Due to the COVID-19 pandemic, Controller Yee postponed the unclaimed property reporting deadlines for life insurance holders, as authorized under Code of Civil Procedure sections 1530 and 1532. This extension results in the following:
• Notice Reports: The final filing date for life insurance companies to submit their Holder Notice Reports is postponed from April 30, 2020 to June 30, 2020.
• Remit Reports and Remittances: The 2020 Holder Remit Reports and Remittances for life insurance companies will be due February 1 - 15, 2021.
Holders or agents of holders who have the ability to submit their Notice Reports by the original April 30, 2020 due date may proceed. The California Unclaimed Property
Division continues to process unclaimed property reports and claims.
https://www.sco.ca.gov/upd_rptg_notice.html05/02/20 8:59 AM
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Connecticut
At this time Connecticut’s statutory reporting deadline has not changed – March 30, 2020. However, the state is asking everyone to send in the report as quickly as possible. The state also indicates that due to the current circumstance, they will accept an e-signature and will accept reports without notarization. CT is asking all holders to submit whatever report documents they can in hard copies with the check, or details of the ACH/Wire payment, and try to follow the format outlined on their website: https://portal.ct.gov/OTT/Unclaimed-Property/Forms-and-Instructions [portal.ct.gov]. If a notary is not available, they are accepting coversheets without notarization. If physical documents can’t be sent, a scan/electronic copy of the signed coversheet along with details of the payment can be submitted to: CTHolderReport@ct.gov.https://portal.ct.gov/OTT/Unclaimed-Property/Forms-and-Instructions04/01/20 2:30 PM
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Delaware
Delaware’s spring reporting deadline for most holders (excluding insurance companies and banking organizations) was March 1, 2020. The state’s Office of Unclaimed Property understands that holder business operations are likely to be impacted by the coronavirus. Holders are encouraged to file their annual reports and remit payment and securities as soon as feasible. Those holders that require an extension for filing their annual report will be granted a 30-day extension upon written request to Escheat.holderquestions@delaware.gov. Additional extension requests should also be submitted in writing to the same email address.https://unclaimedproperty.delaware.gov/04/01/20 2:30 PM
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District of Columbia
Due Diligence: The District of Columbia will consider and plan to approve extensions for holders who couldn’t meet the due diligence requirements during the current stay-at-home guidelines imposed by most states. The District of Columbia understands that this will prolong the reporting process and that holders will subsequently need an extension for the fall reporting cycle.

The District of Columbia Unclaimed Property Office will be operating remotely from 3/16/2020 through 04/27/2020. Holders must file their reports through the Web Portal. Requests for extensions should be emailed to: <a href="mailto:dcunclaimed.property@dc.gov">dcunclaimed.property@dc.gov</a>.
https://cfo.dc.gov/service/unclaimed-property05/04/20 5:26 PM
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Illinois
A further extension to June 30, 2020, will be granted automatically based on extended stay-at-home orders. If the holder requested via email and were granted the 30-day extension you will need to send another request to be granted the extension to June 30, 2020.

The Illinois State Treasurer’s Office, Unclaimed Property Division understands that businesses are likely to be impacted by COVID-19 and subsequent business interruptions. A 30-day extension will be automatically granted to all annual reports due by April 30, 2020 for requests submitted via email to up_report@illinoistreasurer.gov. Administrative rules require extension requests be received at least 15 business days before the due date. Thus, requests should be sent before the close of business on April 9, 2020. Additionally, interest and late-filing penalties will be waived for up to 60 days after the end of the emergency declaration in Illinois
https://icash.illinoistreasurer.gov/05/04/20 5:26 PM
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Indiana
• Reporting Deadline: Indiana does not have any plans to grant automatic extensions. Holders may still file an extension with their office per the instructions on the state website.
• Due Diligence: Indiana is not considering due diligence extensions, but will consider this as a reason for a holder to file a reporting extension request for the November reporting season.
• Foreign Property Owner Due Diligence: Indiana will consider this as a reason for a holder to file a reporting extension request for the November reporting season (The U.S. Postal Service is temporarily suspending service to a long list of countries. This is particularly concerning for the securities industry if they are unable to send due diligence letters to foreign property holders and the potential of unnecessary escheatment as a result).
• Safe Deposit Guidance: Indiana will consider this as a reason for a holder to file a reporting extension request for the November reporting season.

The Indiana Office of the Attorney General Unclaimed Property Division understands that businesses are likely to be impacted by COVID-19 and subsequent business interruptions etc. As a reminder, Holders are able to file an extension with Indiana 30 days prior to the reporting deadline.
https://indianaunclaimed.gov/05/04/20 5:34 PM
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Kansas
Kansas is granting extensions. Holders can request an extension via the extension request form available on their website.https://kansascash.ks.gov/just_for_holders.html03/31/20 11:14 AM
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Kentucky
Any Unclaimed Property Holders required to submit unclaimed property by May 1, 2020 that are unable to report and remit unclaimed property by this deadline can request an extension by emailing the extension form to lferguson@ky.gov by April 15, 2020.https://treasury.ky.gov/unclaimedproperty/Pages/overview.aspx04/01/20 2:25 PM
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Maryland
Maryland has officially moved the 4/30/2020 deadline for insurance company reporting and remittance to 7/31/2020.https://www.marylandtaxes.gov/unclaimed-property/report-property.php04/01/20 2:25 PM
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Massachusetts
The Division is granting a 2-month extension on its Spring reporting deadlines for Life Insurance and Tangible Property. Holders do not need to request a waiver as this is a policy that has been adopted for this year only.https://findmassmoney.com/04/01/20 9:39 AM
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Michigan
Michigan has not made any changes to its July 1 filing deadline. Statute provides holders with an option to request a 60-day extension. The state will take those requests into consideration as they are received.https://unclaimedproperty.michigan.gov/app/reporting-guidelines04/01/20 2:32 PM
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Missouri
Missouri is automatically granting an extension for the May reporting period when receiving an email requesting such. The state’s notice says, “The Missouri State Treasurer’s Office understands that businesses are likely to be impacted by COVID-19 and the subsequent business interruptions, etc. Because of this, holders that require an extension for reporting unclaimed property will be granted a 30-day extension when requested in writing. Holder needing more than 30 days, but not exceeding 90 days, should put the additional time requested in writing. Please reach out to UCP@treasurer.mo.gov with written requests or with any questions.”https://treasurer.mo.gov/UnclaimedProperty/ReportingUnclaimedProperty.aspx03/31/20 11:11 AM
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Nebraska
The Nebraska State Treasurer’s Office recognizes that business operations have been impacted by the COVID-19 health crisis. Life Insurance holders who are unable to submit their report by May 1st should document their extension request through the following link: https://treasurer.nebraska.gov/up/holder-reporting/request-extension.aspx.
Extension requests of up to 90 days will be allowed.
https://treasurer.nebraska.gov/up/04/13/20 9:35 AM
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Nevada
NRS 120A.560 requires insurance companies file holder reports prior to May 1. Given the effects of COVID-19 on individuals and business across the county, Treasurer Conine is granting a blanket extension to all insurance companies. Insurance company reports (for this year only) will now be due prior to June 1, 2020. Reports submitted prior to June 1 will be accepted and not be subject to penalties or interest. Insurance companies that are able to submit reports within the regular filing period (prior to May 1) are encouraged to do so.Nevada Treasurer.Gov04/13/20 9:37 AM
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New Hampshire
Reporting Deadline: No blanket extensions will be put in place, but the state will grant any extensions received. New Hampshire will not assess penalties or interest so long as good faith effort is made.
Report Notarization Waivers: If uploading through state's portal, New Hampshire is not requiring notary. New Hampshire's governor issued an order that notaries do not have to be in person.
Due Diligence: If holders can't perform due diligence, New Hampshire will allow a reasonable time to finish due diligence.
Foreign Property Owner Due Diligence: New Hampshire will provide reasonable time after things are “back to normal.”
https://newhampshire.findyourunclaimedproperty.com/05/04/20 5:59 PM
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New Jersey
To accommodate those affected by COVID-19, the Unclaimed Property Administration will be automatically extending the 2020 Life Insurance reporting deadline to June 30, 2020. There is no need for Holders to file an extension.
The Unclaimed Property Administration per N.J.A.C 17:18-2.4, is allowing holders to first send a due diligence notice by regular mail. Should any notice(s) be returned by the Post Office, the holder shall then send a certified letter with return receipt requested per R.S. 46:30B-50. Holders are not required to send a due diligence letter if the holder's records have already indicated an insufficient or inaccurate address.
https://www.unclaimedproperty.nj.gov/06/26/20 1:10 PM
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North Carolina
North Carolina has extended its deadline for life insurance companies to file Unclaimed Property Holder Reports until June 1, 2020. No Extension Request Form is required for this extension.https://www.nccash.com/holder-information-and-reporting03/31/20 11:11 AM
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Ohio
May 1 is the annual deadline for all life insurance companies to report unclaimed funds for Ohio. If your business needs additional time to file a report, submit a request for an extension. Any additional requests for an extension must be made in writing prior to the expiration of the original extension period. A request for a second extension to the reporting deadline will be granted only for reasonable cause shown and at the discretion of the Department of Commerce, Division of Unclaimed Funds per R.C. 169.03(C). Any questions or concerns should be directed to Ohio Compliance by sending an email to UNFD.Extend@com.state.oh.us.https://apps2.com.ohio.gov/unfd/extension/04/13/20 9:38 AM
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Oklahoma
Reporting Deadline, Due Diligence, Foreign Property Owner Due Diligence, and Safe Deposit Boxes: Holders may request an extension.

During curtailed operations due to the COVID-19 crisis, Oklahoma is temporarily allowing an alternate Verification and Checklist form not requiring a notary. The temporary form can be found in Holder Reporting Forms and Instructions.
https://www.ok.gov/treasurer/Unclaimed_Property/Holder_Information/index.html05/04/20 5:34 PM
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Oregon
Oregon’s online services remain available and the Department of State Land is working. Continue to use Oregon’s website to report unclaimed property.https://unclaimed.oregon.gov/04/01/20 2:25 PM
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Pennsylvania
The statutory deadline for Holders to file and remit unclaimed property remains April 15, 2020. However, the Department will waive all fines, penalties and interest otherwise applicable for all late filed reports and property received by the Department on or before June 15, 2020.

The Pennsylvania Treasury is also granting a waiver for holders that will be unable to report and remit unclaimed property prior to the annual April 15 reporting deadline. For any holders in need of additional time, please notify Treasury via email at report@patreasury.gov.
https://www.patreasury.gov/unclaimed-property/holder/03/31/20 11:14 AM
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Puerto Rico
Extension requests of up to 90 days will be allowed. Puerto Rico has announced in a Circular Letter, CIF-CC-2020-003, dated April 13, 2020, an extension of the government closure due to the COVID-19 until May 3, 2020. The Circular letter states that all financial reports that become due while the government is closed shall be filed on the 15th or 30th day of the month after the date when the report was due once government operations resume. For example, if a report is due on April 30, 2020, and the government opens on May 4th the report is due by May 15th. Ryan LLC has reached out to the jurisdiction for confirmation that the extension applies to unclaimed property reports and will update upon response. In the meantime, consult with your Compliance team for further clarification.http://www.ocif.pr.gov/Pages/default.aspx04/24/20 2:08 PM
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South Dakota
Due Diligence: South Dakota will accept Life Insurance reports prior to June 22 without penalty if the delay is for due diligence.
Foreign Property Owner Due Diligence: South Dakota will allow email contact during this time.

A 30-day extension has been granted to all holders with reports due on May 1, 2020. Reports are now due (postmarked) by June 1, 2020.
https://southdakota.findyourunclaimedproperty.com/05/04/20 5:39 PM
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Texas
Update to Due Diligence Requirements for 2020 Unclaimed Property Reporting:

Section 74.1011 of Texas Property Code requires holders to provide a due diligence 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.
• 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.

If the holder will not be able to provide effective notice to owners before the July 1, 2020, due date, the holder can request a waiver of penalty and/or interest for the properties due for the 2020 report. To submit the request or ask any questions on the due diligence suspension, please contact the Holder Education and Reporting section at up.holder@cpa.texas.gov.

The state has no plans at this time to extend the July 1 reporting deadline. Texas does not have the authority to automatically extend the reporting deadline. However, waivers of penalty and/or interest assessments for property delivered late will be evaluated on a case by case basis.

Foreign Property Owner Due Diligence: While Texas understands the suspension of mail service to certain countries may inadvertently result in some properties being reported as unclaimed property because an owner was not able to receive notice, the state does not have the authority to change or suspend the mailing requirement.

Safe Deposit Boxes: Texas understands the concerns related to the remittance of tangible property and would expect that holders still report tangible property by the filing deadline, July 1. However, Texas will not schedule the delivery of any tangible property until the current situation improves.
https://claimittexas.org/app/what-is-ucp05/22/20 11:41 AM
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Vermont
Vermont is automatically granting an extension for the reporting period when receiving an email requesting such. The state’s notice says, “The Vermont State Treasurer’s Office understands that businesses are likely to be impacted by COVID-19 and the subsequent business interruptions, etc. Because of this, holders that require an extension for reporting unclaimed property will be granted a 30-day extension when requested in writing. Holder needing more than 30 days, but not exceeding 60 days, should put the additional time requested in writing. Please reach out to TRE.UPCompliance@vermont.gov with written requests or with any questions.” Additionally, Vermont is waiving the notary requirements for their unclaimed property reports and will simply accept an e-signature.https://www.vermonttreasurer.gov/content/unclaimed-property03/31/20 11:11 AM
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Virginia
Due to the current teleworking conditions during these challenging times, we are requesting that our holder companies please complete their reporting electronically on www.vamoneysearch.org on our “Click to Report” module. If you are unable to meet the May 1, 2020 deadline, please email us a completed “Request for Extension” form that you can also find on our site and can email to Report.Remit@trs.virginia.gov.https://vamoneysearch.org/Report/Holder-Training/COVID-19-Reporting-Update04/01/20 2:30 PM
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West Virginia
The West Virginia Treasurer’s Office Unclaimed Property Division understands that businesses are likely to be impacted by COVID-19 and subsequent business interruptions etc. As a reminder, Holders can file an extension with West Virginia’s Unclaimed Property office if needed.https://www.wvtreasury.com/Unclaimed-Property/Business-Holders04/01/20 2:30 PM
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