No, we do not believe that the Illinois Revised Uniform Unclaimed Property Act (Illinois RUUPA) provisions regarding “related property” apply to property with common ownership. The Illinois RUUPA provisions regarding related property apply when property is presumed abandoned and other property has accrued or is accruing from that property. Our understanding is that this “related property” rule generally applies to dividends and interest payments that accrue after the underlying security, bond, or similar property is presumed abandoned.

For resources related to our guidance, please see:

• Illinois RUUPA, 765 ILCS 1026/15-209 (“When related property presumed abandoned. At and after the time property is presumed abandoned under this Act, any other property right or interest accrued or accruing from the property and not previously presumed abandoned is also presumed abandoned.”)

• Uniform Law Commission, Revised Uniform Unclaimed Property Act, Section 203, Official Comment (printed page 32) (“Section 209 is not intended to mean that a security is presumed abandoned as a result of a dividend payment being presumed abandoned, nor does it mean that the underlying bond will be presumed abandoned merely because an interest payment with respect to the bond is presumed abandoned. Instead, it is intended to mean that, in the event the security or bond is presumed abandoned as provided in the Act, any future dividend, interest or other property right accruing on such security or bond shall also be presumed abandoned. The section also encompasses cash distributions or accruals on, for example, securities positions, mineral rights, etc. when the underlying property is presumed abandoned.”)