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We reported a safe deposit box as abandoned property under the Uniform Disposition of Unclaimed Property Act. However, after drilling the boxes and doing inventories, we somehow lost track of the contents of the boxes. How should we report this to the State Treasurer? – IBA Compliance Connection

IBA Compliance Connection

Your go to source for compliance!

We reported a safe deposit box as abandoned property under the Uniform Disposition of Unclaimed Property Act. However, after drilling the boxes and doing inventories, we somehow lost track of the contents of the boxes. How should we report this to the State Treasurer?

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From the facts you gave us, we do not see any reason that you would be exempted from reporting the unclaimed property to the state. The Illinois Uniform Disposition of Unclaimed Property Act [Repealed effective 1/1/18] requires banks to report and remit funds and personal property from safe deposit boxes that have been dormant for five years. 765 ILCS 1025/2(d) [Repealed effective 1/1/18]; 765 ILCS 1025/11 [Repealed effective 1/1/18]. There is no exemption in the law or regulations for property that is lost after the safe deposit box is drilled. The Treasurer’s office has been aware of this issue generally for some time and is in the process of developing a formal policy on it, but meanwhile, they are asking that “banks with missing property should report the property, describe as best they can, and include a note that the property is not in the bank’s physical possession.”