Revised Uniform Unclaimed Property Act (RUUPA) Holder Q&A

Revised Uniform Unclaimed Property Act (RUUPA) Holder Q&A

General information

Question

Where can I find the new law? What has changed for reporting in the year 2022? Are there any changes to the priority rules regarding

which state property is reported to?

How do I send in securities included on my report?

Due diligence

When must I send due diligence?

What is the dollar amount cutoff for sending due diligence letters?

Can due diligence letters be emailed?

Were there any other changes to due diligence?

Answer

The Revised Uniform Unclaimed Property Act, which is effective January 1, 2023, can be found on the Washington State Legislature website and is Chapter 63.30.

Nothing has changed for 2022. You will report as usual

for fall 2022. However, our broker and account numbers for reporting securities and mutual funds have changed.

Yes, if there are multiple addresses for an owner, the

state with the most recent address may take custody of the property. If the most recent address is temporary, the state with the next most non-temporary address may take custody. Note: The definition of domicile has changed, please see RCW 63.30.010(6).

We have changed our broker and account numbers for

securities and mutual funds. Please see the Guide to Reporting Unclaimed Property on our website for complete instructions as well as contact and account information.

It depends on when you plan on reporting your property. Letters must be sent by first class mail to the apparent owners. You must wait at least 60 days after you send the letters to the owners before you send in your report. You cannot wait any longer than 180 days from the time you send the letters to the owners. For more information on due diligence, please see RCW 63.30.280. While planning on when to send your mailing, keep in mind that your report is due by October 31 (April 30 for insurance companies).

Due diligence letters need to be sent for any property $75 and over.

If an apparent owner has consented to receive email delivery from the holder, the holder shall send the due diligence letter both by first-class United States mail to the apparent owner's last known mailing address and by email, unless the holder believes that the apparent owner's email address is invalid.

Yes, the content of the due diligence letter is more specific with the new law. The new law outlines the required information. See our reporting guide for an

example with the new requirements. Please see RCW 63.30.290 for detailed content requirements.

Insurance companies

Question

Answer

What is the new due date for reports filed by insurance companies?

Are we still required to file a report for this fall, October 2022?

Effective January 1, 2023, the new reporting date for insurance companies is on or before April 30 of each year. Yes. The reporting requirements for 2022 do not change. All businesses should report as usual for 2022 reporting.

When is the first insurance report due and what property is included in the first report?

The first report under the new law will be due April 30, 2023. Property that became reportable (both one-year and three-year property) during the period beginning July 1, 2022, through December 31, 2022, is due on the first report. See the table below.*

Are we required to use the Death Master File index?

Effective January 1, 2023, the new law cites the use of this file. During an audit, the death master file will be used to check for unclaimed property unless the business has already compared their records to this file. Refer to RCW 63.30.130.

How does RUUPA determine which companies are required to report on the new due date?

RUUPA requires that insurance companies report on the new due date. The new law defines Insurance Company as, "an association, corporation, or fraternal or mutual benefit organization, whether or not for profit, engaged in the business of providing life endowments, annuities, or insurance, including accident, burial, casualty, credit life, contract performance, dental, disability, fidelity, fire, health, hospitalization, illness, life, malpractice, marine, mortgage, surety, wage protection, and worker

compensation insurance," per RCW 63.30.010(13).

*Insurance company transitional reporting (3-year properties)

Upcoming Due Dates

RCW 63.29 due date will be October 31, 2022

April 30, 2023

Reporting Period 7/1/21-6/30/22 7/1/22-12/31/22

Items with Transaction Dates

Between

7/1/18-6/30/19

7/1/19-12/31/19

April 30, 2024, and each year after

1/1/23-12/31/23

1/1/20-12/31/20

Reportable Months

12

6 12

UCP Report Year

2022

2023 2024

Government agencies and courts

Question

Answer

Did our reporting requirements change and when does it take effect?

Yes, there were some changes. Beginning January 1, 2023, the new law states that all government agencies (both state and local) and court held property now becomes reportable one-year after it becomes distributable (as opposed to two-years).

For fall 2022, reporting requirements remain the same.

In fall of 2023, property with last activity dates between July 1, 2020, and June 30, 2022 is due to be reported on or before October 31, 2023.

Financial institutions

Question

Were there any changes to reporting Safe Deposit Box Contents?

What are the changes as to what constitutes positive owner contact?

Can we still charge dormancy fees?

Answer

Reporting requirements did not change. However, protocol for sending contents changed. With the new law, banks are now required to hold contents for 180 days after the report is filed before sending the contents. The Washington State Department of Revenue will continue to notify and send delivery instructions to banks to advise on when contents must be submitted. The new law redefines positive owner contact to now include automatic deposits and withdrawals. Yes, there are certain requirements to do so. An enforceable contract must exist, the holder must regularly impose and not regularly waive or reverse the fees, and the charges must not be unconscionable. Please see RCW 63.30.330 for more information.

For additional information, please visit our holder education page: ucp.dor.app/holder-education

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