New York

The Office of the New York State Comptroller (OUF) oversees the administration of unclaimed property under the Abandoned Property Law (APL). From dormant accounts to uncashed checks and insurance proceeds, New York requires holders to follow strict protocols for dormancy periods, outreach efforts, and reporting. Failing to comply can result in penalties and long-term audit exposure. Here’s what you need to know, and how Eisen can support your compliance journey every step of the way.

New York Escheatment Law Overview

The Abandoned Property Law (APL) requires businesses such as banks, insurers, corporations, and utilities to report and remit property that has remained unclaimed for a defined period of time. The Office of Unclaimed Funds ensures this property is protected until it can be reunited with its rightful owner.

Dormancy Periods in New York

In New York, dormancy periods vary by property type, but most are subject to a three-year threshold. Property is considered dormant if no activity or owner contact has occurred within that time frame.

*Note: Unclaimed virtual currency is subject to a five-year dormancy period (which begins on November 22, 2022, the effective date of APL §1319). The first report for this property will be due on or before November 10, 2028.

Due Diligence Requirements

New York requires holders to make meaningful efforts to reconnect with owners before reporting property as unclaimed. These steps are essential, not just for compliance, but for protecting customer relationships and reuniting owners with their funds.

Due diligence requirements include:

• Send a first-class mail notice to the owner's last known address at least 90 days before filing the final report, regardless of the property's value.
• If there’s no response and the property's value is $1,000 or more, send a follow-up certified mail with return receipt requested at least 60 days before the report is due.
• Banking organizations must also publish notice in a newspaper for property valued over $50, following state-specific publication requirements.

Reporting Requirements and Deadlines

New York's reporting requirements vary depending on the type of holder.

• General Corporations, Broker-Dealers, and Insurance Companies:
  
  • Report Period: January 1 - December 31
  • Report and Payment Deadline: March 10
• Banks and Financial Institutions:
  
  • Report Period: July 1 - June 30
  • Report and Payment Deadline: November 10
• Insurance Companies:
  
  • Report Period: January 2 - January 1
  • Report and Payment Deadline: September 10
• Utility Companies:
  
  • Report Period: July 2 - July 1
  • Report and Payment Deadline: October 10

Reports must be submitted electronically in the NAUPA format. Starting July 1, 2025, New York will only accept NAUPA-formatted reports. Along with the report, holders must:

• Remit payment by Electronic Funds Transfer (EFT), wire or check.
• Transfer securities as per the Security Delivery Instructions.
• Submit the appropriate Verification and Checklist Form.

New York does not require a negative report if no unclaimed property is held.

New York Voluntary Compliance Program

If your business has missed past reporting cycles or identified errors in prior submissions, New York offers a Voluntary Compliance Program. This initiative provides a structured opportunity to correct course without facing immediate penalties.

Participants typically have six months to conduct internal reviews, with a one-time extension of up to 60 days available. To qualify, you have to meet the following criteria:

• First-time reporters of unclaimed funds to the NYS Office of Unclaimed Funds.
• Companies who have not been contacted about an Audit of Unclaimed Funds by NYS.
• Some exceptions can be made to previous reporters on a case by case basis, such as correcting a previous mistake. Contact the Voluntary Compliance Unit (VCU) to check for eligibility.

How Eisen Helps You Stay Compliant in New York

Simplify your escheatment process with Eisen’s comprehensive solutions and escheatment services. Our connected suite of tools helps you manage every stage of compliance, from outreach to remittance:

• Escheatment Manager: Automate your unclaimed property reporting with ease. Eisen’s Escheatment Manager streamlines identification, due diligence, and reporting, minimizing manual efforts and ensuring full compliance with New York’s stringent rules.
• Disbursement Manager: Facilitate efficient remittance of unclaimed property to New York’s Office of Unclaimed Funds. Our Disbursement Manager simplifies payments, reduces administrative burden, and helps you meet critical deadlines with confidence.
• Outreach Manager: Enhance your due diligence process with the Outreach Manager. Engage owners through automated communications, increasing the chance of reconnecting them with their property and strengthening your institution’s commitment to compliance.

At Eisen, we believe compliance shouldn't feel overwhelming. It should feel manageable and empowering. With our solutions by your side, you can navigate New York’s escheatment process with clarity, accuracy, and confidence.