Indiana physician practices should prepare to send due diligence notifications on any unclaimed property during the upcoming 60-day period between July 3 and September 1, 2021. The deadline to report and relinquish unclaimed property will be later this year on November 1, 2021.
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.
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. The Indiana Attorney General’s Unclaimed Property Division has this sample letter on their website for businesses to use.
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)|
|07/01/2019 to 06/30/2020||9/1/2021||11/1/2021|
|07/01/2020 to 06/30/2021||9/1/2022||11/1/2022|
|Three Year Dormancy Period (Most Other Holdings)|
|07/01/2017 to 06/30/2018||9/1/2021||11/1/2021|
|07/01/2018 to 06/30/2019||9/1/2022||11/1/2022|
Submitting a Report
At least 60 days after due diligence is complete, submit an unclaimed property report and relinquish any unclaimed property using the these three steps:
- First, you will create a NAUPA (National Association of Unclaimed Property Administrators) formatted report. First time reporters should contact the Indiana Attorney General’s Unclaimed Property Office with your company name and FEIN and await further instructions.
- 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.
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.
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. Extensions may be granted based on written requests received no later than thirty days prior to the reporting deadline.
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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