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A deceased customer’s checking account has been dormant for three years. We have mailed several notices without receiving a response. Can we report the account as unclaimed property and remit it to the state before we are required to? Are there any consequences for early reporting? – IBA Compliance Connection

A deceased customer’s checking account has been dormant for three years. We have mailed several notices without receiving a response. Can we report the account as unclaimed property and remit it to the state before we are required to? Are there any consequences for early reporting?

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Yes, you may report and remit the account before the Uniform Disposition of Unclaimed Property Act deadline. The Act permits property holders to “report and deliver it prior to the date required for such reporting” if they believe it “will be reportable in the future as unclaimed property.” We are not aware of any consequences for reporting the abandoned property early.

For resources related to our guidance, please see:

  • Uniform Disposition of Unclaimed Property Act, 765 ILCS 1025/11(g) [Repealed effective 1/1/18] (“Any person who has possession of property which he has reason to believe will be reportable in the future as unclaimed property, may report and deliver it prior to the date required for such reporting in accordance with this Section and is then relieved of responsibility as provided in Section 14.”)