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We acquired a bank in 2010. Some accounts were already in dormant status when we purchased them. Can we rely on their inactivity and report them to the state? – IBA Compliance Connection

We acquired a bank in 2010. Some accounts were already in dormant status when we purchased them. Can we rely on their inactivity and report them to the state?

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Under the Uniform Disposition of Unclaimed Property Act [Repealed effective 1/1/18], deposit accounts are presumed abandoned after five years of no communication from the owner or activity on the account (or on any other accounts that appear on the same consolidated statements). 765 ILCS 1025/2(a) [Repealed effective 1/1/18]. If the account owner has not taken any of the specified actions on the account (or any other account or funds at the bank), the account should be presumed to be abandoned — even if the institution that holds the account has changed during the dormancy period.