Holders should be aware that New York is looking to once again bulk up its audit practices. Last year, New York sought to add two internal senior audit staff members. Now, it is looking for external auditors.
Specifically, the New York Office of the State Comptroller has requested bids for third-party audit services for general ledger and/or securities related unclaimed property audits. The Comptroller is looking for up to six firms to "assist in the identification, record analysis and processing, collection and reporting of abandoned property due to the State and held by out-of-state entities" for a five year term. The RFP is open for one month.
New York is likely to initiate new audits in the coming months, as it adds to the audit head count. Companies should review their unclaimed property compliance programs to minimize their risk of being selected for an audit. This includes completing annual filings and avoiding other common audit triggers. If your company does not currently have a compliance program, a Voluntary Disclosure Agreement should be considered to resolve historical liabilities without an audit.