Given the long lookback periods common in unclaimed property audits, record retention is critical. Although exact rules differ by state, companies should generally preserve key records such as the owner’s name and address, property type, and documentation of due diligence, both to demonstrate compliance and defend against audit exposure.
Key Record Retention Requirements
- Retention Period: Most states require records to be retained for 10 years after the reporting year plus the dormancy period — usually three to five years — resulting in a practical retention period of 13 to 15 years.
- State Applicability: With limited exceptions, nearly all states apply the extended retention standard to align with applicable audit lookback periods.
What Records to Retain
Organizations should maintain documentation proving compliance, including:
- Owner-Level Detail: The owner’s name, last known address, and Social Security number or federal employer identification number, if available.
- Transaction-Level Detail: The type of property and any related identifying number, such as an account number or check number.
- Origin of the Property: The date, location, and circumstances giving rise to the property right, such as a check issue date or invoice date.
- Property Value: The amount or value of the property.
- Due Diligence Support: Documentation of efforts made to contact the owner.
- Unclaimed Property Filing Support: Filed reports, state confirmations, remittance support, property details.
Best Practices
- Follow Uniform Act Guidance: The 1981, 1995, and 2016 Uniform Unclaimed Property Acts each recommend retaining records for 10 years plus the applicable dormancy period.
- Prioritize Audit Readiness: Because states frequently conduct audits and might apply estimation or extrapolation when records are unavailable, retaining documentation is far more efficient than attempting to recreate it later.
- Confirm State-Specific Requirements: Organizations should review each state’s unclaimed property handbook or other guidance to verify applicable dormancy periods and record retention requirements.
- Centralized Recordkeeping: Companies should maintain a centralized repository for unclaimed property records capable of preserving documentation for at least 15 years.
How BDO Can Help
- Feasibility Studies: Conduct diagnostic reviews and risk assessments to identify and quantify potential liability.
- Policies & Procedures: Develop tailored unclaimed policies and procedures aligned with your operations.
- Annual Compliance: Assist with annual multistate reporting and the preparation and filing of unclaimed property reports.
- Consulting Support: Provide audit support and defense, voluntary disclosure assistance, and remediation support.
- Training: Offer unclaimed property training for finance, operations, and shared services personnel.
Learn more about our Unclaimed Property services and contact our team to discover how we can help you address your unclaimed property needs.