State Treasurers Waiting for ULC Uniform Act

Last week, Kansas City hosted the 2015 National Association of State Treasurers Treasury Management Symposium. The Symposium hosts state treasurers and their staffs for three plus days of training and networking. This is one of the premier events for state unclaimed property administrators, typically hosting more than 30 different state administrators at one time. In 2014, the major topics included enhancing claims processes and online holder reporting. This year, many of the state discussions focused on the efforts to reform the uniform unclaimed property act, as well as continued improvements relating to claims processes, holder reporting and back office management.

Why Wait?

NAUPA, or the National Association of Unclaimed Property Administrators, is currently working on several modernization projects, including the electronic reporting format, owner relationship codes, and property type codes, as well as a unified online reporting system. Their stated goal is to create uniformity through all the states.

NAUPA has made a lot of progress on the owner relationship codes but not as much on the property type codes. Complications have arisen from just the sheer number of different codes and definitions that the states use. In addition, discussions surrounding the model act have brought forth the possibility of entirely new types of unclaimed property. (BitCoin anyone?) If these new property types are included, we can expect to see even more additional property types in the list of codes. However, NAUPA does not want to proceed with these changes until there is some certainty that they will be included in the model act which would then be presented to state legislatures.

Some of the issues for online reporting include how to gather additional information from holders, like emails and business contact persons, additional characters, longer fields, and potentially a notes section. Property type specific issues arise in the context of securities and mineral interests, so that holders can give information relating to basis, leases and other similar information. There is also a call for a free form "notes" section. Many of the new fields may be determined by what information the model act requires holders to submit with the reported properties. Most states are also asking for clarity in the consolidated holder reporting process. Once NAUPA determines what the system should look like, they have to find the resources to build and implement such a system.

States have only limited resources to allocate to new processes and modernization efforts. Many states have allocated resources to attending and participating in the model act discussions, providing legal analysis and support through whitepapers and otherwise participating in the drafting process. Once the model act is finalized, state administrators will be spending a lot of time, energy and political capital trying to pass the new model act in their own state legislatures.

Resources are also being allocated to the ongoing improvement of the claims systems, with increased automation and response times. The states that have already been through this process reported a dramatic increase in claims volumes after upgrading their systems and publicity efforts. Many states have or are in the process of upgrading the imaging and document storage systems, providing a paperless environment. Several states also commented about new standard operating manuals, to provide standards across the board but particularly for claims processing.

Other Trends

NAUPA has seen a lot of personnel changes over the past year. Some state administrators had been in the job for short periods of time and were trying to learn from their new peers. Some state administrators also announced retirements from long time staff members, which will lead to more turnover in the state unclaimed property offices. Many of these personnel changes involve decades worth of experience and institutional knowledge. Holders can expect some additional changes in policies and regulations as new administrators and staff become fully immersed in their new roles (as well as more personnel changes, including retirements, soon after the new model act is passed on the state level).

This year's conference also featured many new auditors, in addition to the well known auditors like Kelmar, Verus and UPCH/Xerox. In speaking with these new auditors, their goals appear to be faster and more efficient audits and they looking for new property types and sources of unclaimed property. Administrators do not see a large expansion of Social Security Death Master File (SSDMF) matching beyond life insurance and securities except perhaps under audit situations.

The 2016 Symposium will be in New Orleans, Louisiana.

See Also:
New York Requesting Bids for Auditors
How Confidential are Auditor Workpapers?
Delaware Implements Some Task Force Recommendations