Unclaimed Property

We gather facts through stakeholder interviews and targeted data requests to understand your organization’s unclaimed property profile, reporting history, legal entity footprint, systems, and current compliance processes. We also evaluate the types of property generated by the business, how those items are tracked and aged, and whether historical practices align with applicable state requirements.  Based on state dormancy periods, due diligence rules, priority rules, and reporting standards, we identify potential exposure areas and the jurisdictions where compliance obligations may exist.

Our feasibility analysis is designed to provide a practical view of your current risk profile and help determine the most appropriate path forward.  This may include identifying gaps in historical reporting, assessing record availability, evaluating potential estimation exposure, and outlining remediation options such as voluntary disclosures, amnesty programs, prospective compliance, or process improvements.

After quantifying potential exposure by state and property type, we provide a recommended course of action tailored to your organization’s risk profile, reporting history, and compliance objectives. Our recommendations are designed to help prioritize jurisdictions, address historical liabilities efficiently, and align the remediation approach with the quality of available records, the nature of the property involved, and the states most likely to assert exposure.

This may include assistance with voluntary disclosure agreements, amnesty programs, and other state-sponsored resolution programs, as well as support with prospective compliance, historical clean-up, due diligence, and the preparation of required filings. Where appropriate, we also help evaluate the relative benefits of different remediation paths, including penalty and interest mitigation, lookback considerations, and the administrative demands associated with each option.

We understand the unclaimed property laws, reporting requirements, and operational challenges that affect your business, including the complexity that can arise across multiple legal entities, business units, systems, and property types. Our approach to annual compliance is designed to improve accuracy, reduce risk, and create a more consistent and defensible reporting process by aligning data gathering, property classification, dormancy tracking, due diligence, and reporting procedures across your organization. We work with clients to help establish a repeatable compliance framework that supports timely reporting, enhances documentation, and helps reduce the likelihood of errors that can lead to penalties, interest, or future audit scrutiny.

We can assist with the full annual compliance cycle, including holder reporting, negative reporting where applicable, due diligence letter requirements, owner outreach, and the preparation of amended or supplemental reports. Where needed, we also help refine internal procedures and support communication among tax, accounting, treasury, legal, accounts payable, payroll, and other stakeholders involved in the compliance process.

We advocate on your behalf in unclaimed property audits and other state inquiries by providing strategic guidance, coordinating audit response efforts, managing information requests, and developing practical resolution strategies tailored to your facts and objectives. Our team assists with multistate audits, third-party contract audit firms, estimation challenges, document reconstruction efforts, state correspondence, settlement discussions, and appeals support where needed. We help clients navigate the procedural and technical issues that often arise during an examination, including scoping disputes, record-availability issues, sampling and estimation methodologies, priority rule application, and questions regarding reportability, dormancy, and jurisdiction.

Throughout the process, we work to help you manage risk, reduce business disruption, and maintain control over the audit. Our approach is focused on organizing and presenting information efficiently, evaluating the reasonableness of state positions, identifying opportunities to narrow exposure, and supporting defensible outcomes.  Where appropriate, we also assist in developing parallel remediation or prospective compliance strategies to address broader risk areas identified during the audit process.

Our team supports clients in mitigating future unclaimed property exposure by developing, enhancing, and implementing comprehensive unclaimed property policies and procedures that can be applied across each entity. We also review existing documentation to help ensure consistency across all entities. Our approach focuses on establishing a robust unclaimed property framework, including identification of relevant property types and bank accounts, segregation of escheatment liability account(s), and alignment of reporting calendars. 

Throughout the process, we provide actionable recommendations and process improvements designed to support ongoing compliance. We access the current state to identify gaps and enhancements, define roles and responsibilities across functions, and standardize identification and dormancy tracking by property type.  Documented procedures support a process that helps reduce risk, enhance efficiency, and support proactive compliance.

We analyze the unclaimed property implications of mergers, acquisitions, divestitures, and internal reorganizations to help identify historical exposures, operational risks, and compliance gaps that may affect transaction value or post-close obligations. We perform both buy-side and sell-side due diligence to help quantify risk, assess the reasonableness of existing practices, and identify issues that may warrant specific indemnities, purchase price adjustments, remediation planning, or post-closing action.

We also assist with post-transaction planning by helping clients address integration-related compliance challenges and align unclaimed property processes across the combined organization. This may include evaluating how property is identified and tracked across legacy systems, standardizing policies and procedures, clarifying reporting responsibilities among entities and functions, and establishing a more consistent framework for due diligence, reporting, and record retention going forward.

Our risk assessment services begin with an understanding of your organization’s priorities, immediate concerns, and long-term compliance objectives. We perform a focused evaluation of your overall unclaimed property profile to help identify the areas of greatest exposure, key risk drivers, and potential opportunities to reduce future liability. Unlike an annual compliance engagement or a remediation project, this service is designed to provide a broader perspective on your unclaimed property posture and help management better understand where attention should be directed.

Based on this assessment, we provide practical, risk-focused insights to help your organization make informed decisions and strengthen its overall compliance position.  This may include identifying areas of heightened exposure, evaluating governance and data-related risks, considering the impact of historical filing gaps or record limitations, and helping prioritize actions that can reduce the likelihood of audit scrutiny, estimation, penalties, or ongoing noncompliance. Our approach is intended to be efficient, minimally disruptive, and valuable as an early-stage assessment before undertaking more targeted compliance or remediation efforts.

We assist with estimating potential unclaimed property exposure for internal risk assessment, financial reporting, transaction planning, and audit readiness purposes.  Our approach includes reviewing historical reporting practices, legal entity and filing footprints, available books and records, and applicable state estimation methodologies to develop reasonable exposure calculations and identify areas requiring remediation. Where records are incomplete, we help assess the extent to which estimation may apply and evaluate the assumptions, methodologies, and data points that may be relevant in quantifying potential liability across states and property types.

We work collaboratively with your internal stakeholders and other advisors to provide practical, supportable analyses tailored to your objectives. This may include helping management understand key exposure drivers, prioritizing jurisdictions for remediation, evaluating the potential impact of voluntary disclosure or other resolution options, and developing a clearer view of unclaimed property risk for planning and decision-making purposes.