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How long should we retain the dormant account notices that we mail to the customer? What about the rest of the dormant account documentation? Do we need to retain that documentation permanently? – IBA Compliance Connection

IBA Compliance Connection

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How long should we retain the dormant account notices that we mail to the customer? What about the rest of the dormant account documentation? Do we need to retain that documentation permanently?

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No, you do not need to retain dormant account documentation permanently. The Uniform Disposition of Unclaimed Property Act requires the holder of a dormant account to retain records for five years after the account is presumed abandoned, which generally occurs after five years of inactivity.  We believe the five-year record retention requirement also applies to the dormancy notices that you must send to your customers under the Act.  

For resources related to our guidance, please see:

  • Uniform Disposition of Unclaimed Property Act, 765 ILCS 1025/11(h)(2) [Repealed effective 1/1/18] (“[P]roperty records . . . shall be retained for 5 years after the property was reportable.”)\
  • Illinois Uniform Disposition of Unclaimed Property Act, 765 ILCS 1025/2 [Repealed effective 1/1/18] (Establishes the abandonment periods for unclaimed property held by financial organizations, including banks)
  • Uniform Disposition of Unclaimed Property Act, 765 ILCS 1025/11(e) [Repealed effective 1/1/18] (“[T]he holder of property presumed abandoned under this Act shall communicate with the owner at his last known address if any address is known to the holder, setting forth the provisions hereof necessary to occur in order to prevent abandonment from being presumed.”)