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Under the new Illinois unclaimed property law, what is the time period covered by each annual report? Under the old law, we reported accounts as of June 30 of each year. – IBA Compliance Connection

IBA Compliance Connection

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Under the new Illinois unclaimed property law, what is the time period covered by each annual report? Under the old law, we reported accounts as of June 30 of each year.

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The Illinois Revised Uniform Unclaimed Property Act (Illinois RUUPA) requires that annual reports of unclaimed property “cover the 12 months preceding July 1 of that year.” In other words, the period covered for annual reports filed under the new law is the same as the period covered for annual reports filed under the previous law. For example, a report filed on November 1, 2018, must include property that became unclaimed through June 30, 2018.

Note that the initial report filed under the new law also must cover a five-year lookback period. This initial report must include “all items of property that would have been presumed abandoned during the 5-year period preceding the effective date of this Act as if this Act had been in effect during that period.” Thus, the first report filed no later than November 1, 2018, also must include property that became unclaimed between January 1, 2013, and January 1, 2018, if not previously reported.

For resources related to our guidance, please see:

  • Illinois RUUPA, 765 ILCS 1026/15-403(a) (Requires a report of unclaimed property to be “filed before November 1 of each year and cover the 12 months preceding July 1 of that year. Business associations which must report under this subsection (a) include financial organizations . . . .”)
  • Illinois RUUPA, 765 ILCS 1026/15-1503(a) (“An initial report filed under this Act for property that was not required to be reported before the effective date of this Act, but that is required to be reported under this Act, must include all items of property that would have been presumed abandoned during the 5-year period preceding the effective date of this Act as if this Act had been in effect during that period.”)