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When reporting unclaimed property, should a bank holding company follow the reporting deadlines for a banking organization or for a business association? – IBA Compliance Connection

IBA Compliance Connection

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When reporting unclaimed property, should a bank holding company follow the reporting deadlines for a banking organization or for a business association?

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We believe that a bank holding company should be considered a “business association” under the Uniform Disposition of Unclaimed Property Act. The Act defines “banking organization” and “financial organization” to include several types of banks, but neither definition encompasses a bank holding company. Therefore, property held by the holding company (and not held by the bank) should be reported on May 1, the deadline for business organizations, rather than November 1, the deadline for banks.

For resources related to our guidance, please see:

  • Uniform Disposition of Unclaimed Property Act, 765 ILCS 1025/11(d) [Repealed effective 1/1/18] (Business associations must report unclaimed property by May 1, and banking organizations must report unclaimed property by November 1.)
  • Uniform Disposition of Unclaimed Property Act, 765 ILCS 1025/1(b) [Repealed effective 1/1/18] (“Business association” includes corporations, joint stock companies, business trusts, partnerships, etc.)
  • Uniform Disposition of Unclaimed Property Act, 765 ILCS 1025/1(a) [Repealed effective 1/1/18] (“Banking organization” means “any bank, trust company, savings bank, industrial bank, land bank, safe deposit company, or a private banker.”)
  • Uniform Disposition of Unclaimed Property Act, 765 ILCS 1025/1(c) [Repealed effective 1/1/18] (“Financial organization” means “any savings and loan association, building and loan association, credit union, currency exchange, co-operative bank, mutual funds, or investment company.”)