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Does Illinois law determine when we must consider an account to be dormant? We want to extend the period before we start mailing notices to the customer, and we don’t want to wait until the time periods required by the Unclaimed Property Act. – IBA Compliance Connection

IBA Compliance Connection

Your go to source for compliance!

Does Illinois law determine when we must consider an account to be dormant? We want to extend the period before we start mailing notices to the customer, and we don’t want to wait until the time periods required by the Unclaimed Property Act.

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We are not aware of anything in Illinois law that would restrict your ability to mail notices to a customer regarding a dormant account. The Uniform Disposition of Unclaimed Property Act imposes an affirmative requirement to attempt to communicate with customers before reporting their property as abandoned. 765 ILCS 1025/11(e) [Repealed effective 1/1/18]. However, nothing in that law would prevent you from mailing notices to customers before those requirements kick in. Other than requirements that may apply under your account agreements, we are not aware of any other restrictions on communicating with customers regarding their accounts when your policies and procedures determine that the accounts are dormant.