California Requires Controller to Implement Plan to Increase Unclaimed Property Compliance

On September 27, 2019, California Senate Bill 109 (S.B. 109) was enacted to amend certain parts of the California Budget Act of 2019.  One of the features of S.B. 109 relates to California unclaimed property reporting, as follows:
On or before March 1, 2020, the Controller shall provide the Joint Legislative Budget Committee and the chairpersons of the fiscal committees in each house of the Legislature with a report on plans to provide for a one-time unclaimed property amnesty, or other options to increase compliance with unclaimed property law in lieu of an amnesty program, and options for increasing the return of unclaimed property to rightful owners.
Based on the language of S.B. 109, the Controller will have the option to implement an unclaimed property amnesty program, to implement other requirements to increase unclaimed property compliance, or to do both.
This is the third bill enacted by California in 2019 dealing with different aspects of unclaimed property reporting.  It appears safe to assume that California is planning to not only target holders that are not complying with California unclaimed property reporting, but to also look at unclaimed property as a potential revenue source for the state. As a result, it is important for companies to review their unclaimed property practices and procedures to determine whether potential exposure exists with respect to California unclaimed property reporting and compliance requirements. 
Please consult with a member BDO’s Unclaimed Property group to discuss these issues.