United States

New York revises unclaimed property voluntary compliance agreement


Recently, the New York State Comptroller quietly revised the 2017 unclaimed property voluntary compliance agreement reducing the reportable period reach-back to 2007 for “general ledger” type property. This is a significant reduction in reach-back as the prior reporting periods included in the agreement began with report year 1996. The revised reach-back is only available for new entrants into the voluntary compliance program.

Accordingly, the revised reach back includes the following property issued in 2003:

  • Unclaimed wages
  • Accounts payable checks
  • Refund checks
  • Rebate checks issued and/or payable

It also includes accounts payable and receivable credits, including merchandise credits and gift certificates, issued in 2001.

The audit reach back period remains Jan. 1, 1992, for general ledger items. Applicable statutory periods apply to property other than general ledger items, such as debt and equity.

Holders eligible for voluntary compliance include first-time reporting organizations, and in some instances, entities that have filed in the past, but recognize that they have failed to report a particular type of property and have come forward voluntarily to correct the error. Holders that have been contacted for an unclaimed property audit are ineligible for voluntary compliance.

In order to participate, eligible holders must contact the Comptroller or submit a voluntary disclosure agreement. Benefits to participation include the reduced reach-back and six months to file the report without interest or penalties.

If you are holding unclaimed property and are considering entering into the New York voluntary compliance program it is important to understand these changes and how they may impact your participation.  

Catherine Del Re


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