Unclaimed Property Reporting – New Pennsylvania “Due Diligence” Deadline Approaching
In the fall of 2016, a new “due diligence” requirement was added to Pennsylvania’s unclaimed property law. Holders of reportable property valued at $50 or more are now required to send notice to the owner of the property no more than 120 days and no less than 60 days before the holder’s unclaimed property report is to be submitted to the Treasury Department, if they have an address for the owner that is not known to be inaccurate. See 72 P.S. § 1301.10a. The filing deadline for 2016 unclaimed property reports is April 17, 2017. Therefore, the statutory deadline for sending the required notices is February 16.
The required notice must include (1) a description of the property, (2) a description of the property ownership, (3) the value of the property, if known, and (4) contact information for the holder. The written notice must be sent by first class mail unless the owner has previously agreed to a method of electronic notice. Holders are required to submit an affirmation of compliance with the “due diligence” requirements with their unclaimed property reports. No costs or fees may be imposed on property owners with respect to issuance of the required notices.
If a property owner reaches out to the holder before the unclaimed property report is filed, the property will not be reportable as unclaimed property if it is returned to the owner or the owner “indicates an interest in” the property.