Indiana physician practices have just two days to report and relinquish unclaimed property to meet the November 1, 2020, deadline.
Unclaimed property consists of any financial asset with no account activity by its owner for a specified period of time, or what’s known as a dormancy period. The dormancy period is one year for payroll, wages, and utilities, and three years for most other holdings. Wages or commissions; savings and checking accounts; escrow funds; health savings accounts; stock dividends; insurance proceeds; underlying shares; customer deposits or overpayments; certificates of deposit; credit balances; refunds; money orders; and safe deposit box contents all fall under Indiana’s Unclaimed Property Act.
Due Diligence
Indiana’s Unclaimed Property Act requires due diligence be performed on all unclaimed property of $50 or more so that the property of an owner who has an ongoing relationship with the holder or whose last known address in the holder’s records is a current address doesn’t get swept up in the unclaimed property process
Due diligence includes sending notifications about the unclaimed property and how to retrieve it to the owner’s last known address by first class mail or better. Those notifications must be sent no more than one hundred twenty days and no less than sixty days prior to the filing of the report. That means due diligence notifications should be sent between July 3 and September 1 to comply with the November 1 deadline for reporting and relinquishing unclaimed property.
Timelines at a Glance
Putting all that together, there are three different dates to keep in mind each year based on the dormancy period, the due diligence deadline, and the reporting deadline.The dormancy periods run from July-June for any activity that took place in the year or three years prior. See the chart below for more details:
| Items that were issued or had a last activity date during: | Due Diligence to be performed no later than: | Date to be Reported: |
| One year Dormancy Period (Payroll, Wages & Utilities) | ||
| 07/01/2018 to 06/30/2019 | 9/1/2020 | 11/1/2020 |
| 07/01/2019 to 06/30/2020 | 9/1/2021 | 11/1/2021 |
| Three Year Dormancy Period (Most Other Holdings) | ||
| 07/01/2016 to 06/30/2017 | 9/1/2020 | 11/1/2020 |
| 07/01/2017 to 06/30/2018 | 9/1/2021 | 11/1/2021 |
Submitting a Report
Submitting an unclaimed property report electronically is easy. Just follow these three steps:
- First, you will create a NAUPA (National Association of Unclaimed Property Administrators) formatted report using UPExchange.
- Next, once your report is created and formatted to NAUPA standards, you will submit it via the Indiana Unclaimed Property Website.
- Finally, you will submit your payment either online or by mailing a copy of your Holder Summary and a check payable to “State of Indiana” to: Office of the Indiana Attorney General Unclaimed Property Division, 35 South Park Blvd, Greenwood, IN 46143.
Zero Reports
Even in the case of a “Negative” or “Zero” annual report reflecting no unclaimed property held by the holder or business enterprise, the attorney general encourages annual submission of unclaimed property reports, although such zero reports are not statutorily required. According to the Unclaimed Refunds FAQ page, most corporate legal and accounting advisors deem negative reporting a best governance practice, demonstrating an entity’s awareness of the legal requirements of the unclaimed property act, prompting an annual review, and keeping the organization in good standing with the State.
Penalties
The penalties for failing to report unclaimed property in Indiana are $100 per day, up to $5,000. A holder who intentionally fails to pay or deliver property is subject to an additional civil penalty of 10 percent of the value of the property that must be paid or delivered. A holder that willfully refuses to pay after written notice commits a Class B misdemeanor. While extensions may be granted, the deadline for making such a written request, which is no later than thirty days prior to the reporting deadline, has passed.
For more information, review the Indiana Unclaimed Property Act or visit the Indiana Attorney General’s Report Unclaimed Property Reporting FAQs webpage. For information about reporting unclaimed property in other states, begin with the National Association of Unclaimed Property Administrators (NAUPA) Reporting Resources website.
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