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In the new Illinois unclaimed property law, there is a requirement to include the name and last-known address of the beneficiary for “a life or endowment insurance policy, annuity contract, or other property where ownership vests in a beneficiary upon the death of the owner.” Would this requirement apply to payable on death (POD) and IRA beneficiaries? – IBA Compliance Connection

In the new Illinois unclaimed property law, there is a requirement to include the name and last-known address of the beneficiary for “a life or endowment insurance policy, annuity contract, or other property where ownership vests in a beneficiary upon the death of the owner.” Would this requirement apply to payable on death (POD) and IRA beneficiaries?

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Yes, the reporting of beneficiary information applies to POD and IRA beneficiaries, as for other types of property for which “ownership vests in a beneficiary upon the death of the owner.”

We contacted an attorney at the Illinois Treasurer’s office, who confirmed that this provision applies to POD and IRA beneficiaries. The State Treasurer’s intent is to use this beneficiary information to distribute unclaimed property to the appropriate beneficiaries, if they make a claim for the property. Without beneficiary information, the Treasurer would have to treat the property as owned by the decedent’s estate.

For resources related to our guidance, please see:

  • Illinois Revised Uniform Unclaimed Property Act, 765 ILCS 1026/15-402(a)(5) [Effective 1/1/18] (The report made by a holder must “for an amount held or owing under a life or endowment insurance policy, annuity contract, or other property where ownership vests in a beneficiary upon the death of the owner, contain the name and last-known address of the insured, annuitant, or other apparent owner of the policy or contract and of the beneficiary.”)