Yes, we believe that you may wait before reporting and delivering the CD as unclaimed property until the next applicable reporting date after it matures in 2022.

Under the Illinois Revised Uniform Unclaimed Property Act (Illinois RUUPA), an automatically-renewable CD would be presumed abandoned three years after the most recent indication of interest “following the completion of the initial term of the time deposit and one automatic renewal term of the time deposit.” However, the Illinois RUUPA states that automatically-renewable time deposits do not need to be reported and delivered to the Treasurer when doing so would cause the owner to pay a penalty or forfeit interest. Instead, you may delay reporting and delivering the CD to the Treasurer until a penalty or forfeiture of interest would no longer result from delivery of the property to the Treasurer.

When the CD reaches its next maturity date, you would report and deliver the property on your next applicable reporting date (which would be November 1 for a bank) and indicate in your report that “the property is being reported on an extended date pursuant to” Section 15-603(b) of the Illinois RUUPA.

You are not required to remit a CD as a cashier’s check to the Illinois Treasurer. The Treasurer accepts electronic payments and payments by ACH.

For resources related to our guidance, please see:

• Illinois RUUPA, 765 ILCS 1026/15-201 (“Subject to Section 15-210, the following property is presumed abandoned if it is unclaimed by the apparent owner during the period specified below: . . . (iv) an automatically renewable time deposit for which the owner consented to the automatic renewal in a record on file with the holder, 3 years after the date of last indication of interest in the property by the apparent owner, following the completion of the initial term of the time deposit and one automatic renewal term of the time deposit; . . .”)

• Illinois RUUPA, 765 ILCS 1026/15-603(b) (“If property in a report under Section 15-401 is an automatically renewable time deposit and the holder determines that a penalty or forfeiture in the payment of interest would result from paying the deposit to the administrator at the time of the report, the date for reporting and delivering the property to the administrator is extended until a penalty or forfeiture no longer would result from delivery of the property to the administrator. The holder shall report and deliver the property on the next regular date prescribed for reporting by the holder under this Act after this extended date, and the holder shall indicate in its report to the administrator that the property is being reported on an extended date pursuant to this subsection (b).”)

• Illinois Treasurer, Reporting Guidelines (“Report Remittance Information:

  Remittances may be made via check or ACH Credit. To receive Illinois’ ACH instructions, email your request to [email protected]. Please supply your fax number and the instructions will be faxed to you.

  Checks should be made out to Illinois State Treasurer.”)

• Illinois Treasurer, Holder Payment Portal