IBA Compliance Connection

Your go to source for compliance!

Under the new Illinois unclaimed property law, we understand that no notice is required for property valued at less than $50 (or less than $1,000 for securities). Is there a de minimis amount for accounts that must be sent to the Treasurer?

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No, the Illinois Revised Uniform Unclaimed Property Act (Illinois RUUPA) does not have a de minimis threshold for remitting property to the Illinois Treasurer. While you do not need to send a notice to the apparent owner for property valued at less than $50, you still must submit such property to the State Treasurer per the Illinois RUUPA’s rules.

For resources related to our guidance, please see:

  • Illinois RUUPA, 765 ILCS 1026/15-603(a) (“Except as otherwise provided in this Section, on filing a report under Section 15-401, the holder shall pay or deliver to the administrator the property described in the report.”)
  • Illinois RUUPA, 765 ILCS 1026/15-501(a) (“ . . . the holder of property presumed abandoned shall send to the apparent owner notice by first-class United States mail . . . if: . . . (2) the value of the property is $50 or more.”)
  • Illinois RUUPA, 765 ILCS 1026/15-501(c) (“ . . . the holder of securities presumed abandoned . . . shall send to the apparent owner notice by certified United States mail . . . if: . . . (2) the value of the property is $1,000 or more.”)
  • Illinois RUUPA, 765 ILCS 1026/15-402(b) (“A report under Section 15-401 may include in the aggregate items valued under $5 each. If the report includes items in the aggregate valued under $5 each, the administrator may not require the holder to provide the name and address of an apparent owner of an item unless the information is necessary to verify or process a claim in progress by the apparent owner.”)