With House Bill 420, Tennessee has introduced many changes
to unclaimed property compliance rules. These new rules will impact the
Tennessee report that is due by May 1st, 2018. Are you ready to
comply with the new legislation?
The legislation widens the window for due diligence
letters to go out. Previously, the letters were to be sent 120 to 60 days
before the report due date. Now, the letters must be sent 180 to 60 days before
the report due date. Make sure to have your letters sent by June 1, 2018 for
this year.
The dormancy period for many property types changed from 5
years to 3 years. Make sure to review your property records based on the new
dormancy so that you report everything on time.
Payment must be made on the state’s website at
the time you upload your state report file. You will want to contact your
accounts payable department soon to make sure you can successfully submit the
required ACH payment. You may have a debit block on your account. If this is
the case, contact your financial institution prior to making payment and give
them the state’s company Id # U626001445 to allow the upcoming transaction.
What if you are not able to make the required ACH payment?
If your company is not able to make the ACH payment, you will want to apply for
a one-year waiver. To state the process of requesting a waiver, email the state
at UCP.holders@tn.gov. Make sure to get
the waiver in place well before the report due date.
If you rely on a software vendor to have these compliance
changes in place, contact their support or compliance department to verify they
have implemented the required changes.