How does escheatment reporting work across multiple states?

Escheatment reporting across multiple states usually means you have to determine which state has the right to claim abandoned property, then report and remit according to that state’s rules. The tricky part is that each state has its own lookback periods, dormancy rules, due dates, filing methods, and required holder due diligence.

Here’s the basic framework:

1) Determine the property type and owner address

For each item of unclaimed property, you generally first look at:

• Property type: payroll, vendor checks, customer credits, uncashed dividends, gift cards, securities, etc.
• Owner’s last known address: this usually determines the state to report to.
• If no address exists, the rules often default to the holder’s state of incorporation for many property types.

2) Apply the state priority rules

States generally follow priority rules from the U.S. Supreme Court cases Texas v. New Jersey and Pennsylvania v. New York:

1. Primary rule: Report to the state of the owner’s last known address, if you have one.
2. Secondary rule: If no address is known, report to the holder’s state of incorporation/domicile.

Some property types or states may have exceptions, but this is the general baseline.

3) Use each state’s dormancy period

A property becomes reportable only after its dormancy period passes. This varies by state and property type.

Examples:

• Payroll: often 1–3 years
• Vendor checks: often 3–5 years
• Uncashed customer refunds: often 3–5 years

Because dormancy periods differ, the same item may be reportable in one state but not another.

4) Perform due diligence before reporting

Most states require you to send a due diligence letter to the owner before filing if the property value exceeds a threshold. This letter tells the owner how to claim the property and gives them a chance to respond.

5) File separate reports by state

If you have property owed to multiple states, you typically must:

• Prepare a separate report or state-specific filing for each state
• Follow each state’s required format, usually electronic
• Submit remittance/payment by the state’s deadline

Many states accept reports through software or the NAUPA format, but requirements differ.

6) Remit by state deadline

Filing deadlines vary, but many states have annual deadlines in the fall. Some states have different due dates depending on holder type.

7) Maintain supporting records

You usually need to keep records for several years showing:

• Owner name/address
• Property type and amount
• Dormancy calculations
• Due diligence attempts
• Filing confirmations
• Check/register details

8) Multi-state holders often need a compliance process

If you operate in many states, you’ll usually want a centralized process to:

• Identify abandoned property across systems
• Map each record to the right state
• Track dormancy by property type and state
• Generate due diligence letters
• Create state-specific filings
• Reconcile remittances and claims

Common complications

• Different dormancy periods by state and property type
• Owner address quality issues
• State-specific exemptions
• Gift card and loyalty program rules
• Securities and dividends requiring different reporting methods
• Audit exposure if records are incomplete or inconsistent

Practical example

Suppose you have:

• A payroll check for an employee last known in Illinois
• A vendor check with no address
• A customer refund for someone in California

You would typically:

• Report the payroll item to Illinois
• Report the no-address vendor item to your state of incorporation
• Report the customer refund to California

If you want, I can also give you:

1. a step-by-step multi-state escheatment workflow,
2. a state priority rules chart, or
3. a sample reporting calendar.