The answer to your first three questions is yes — all of those activities constitute indications of interest in a CD that would prevent the presumed abandonment period from running.

The Illinois Revised Uniform Unclaimed Property Act (Illinois RUUPA) would treat the transfer of accrued interest from a CD account as an indication of interest — such a transfer would result in a decrease in the CD account funds, which qualifies as an indication of interest. Also, when a customer cashes a check issued for interest that accrued on a CD account, the customer has made an indication of interest by presenting an interest payment check for the account.  

If a CD customer has other accounts at your bank sharing the same mailing address, your institution may rely on certain indications of interest in an active account for other inactive accounts. For example, if a customer increases or decreases account funds or engages in any other relationship with your institution, such as making a loan payment, those actions also will qualify as indications of interest the customer’s inactive accounts at your institution.

We do not entirely agree with your final statement — the fact that a customer has other accounts with your institution does not necessarily prevent an inactive account from becoming unclaimed property. Your bank still would have to ensure that the customer has engaged in qualifying activities in an active account, such as increasing or decreasing the account funds or engaging in other relationships, such making payments on a loan.

For resources related to our guidance, please see:

• Illinois RUUPA (effective January 1, 2018), 765 ILCS 1026/15-210(b) (“Under this Act, an indication of an apparent owner’s interest in property includes: . . . (4) activity directed by an apparent owner in the account in which the property is held, including accessing the account or information concerning the account, or a direction by the apparent owner to increase, decrease, or otherwise change the amount or type of property held in the account

• Illinois RUUPA (effective January 1, 2018), 765 ILCS 1026/15-210(b) (“Under this Act, an indication of an apparent owner’s interest in property includes: . . . (3) presentment of a check or other instrument of payment of a dividend, interest payment, or other distribution, or evidence of receipt of a distribution made by electronic or similar means, with respect to an account, underlying security, or interest in a business association; . . .”)

• Illinois RUUPA (effective January 1, 2018), 765 ILCS 1026/15-210(f) (“. . . activity directed by an apparent owner in any other accounts, including loan accounts, at a financial organization holding an inactive account of the apparent owner shall be an indication of interest in all such accounts if: