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Are we correct that under the new Illinois unclaimed property law, the presumed abandonment period for a certificate of deposit (CD) begins after the initial renewal date — not allowing for one automatic rollover as under the previous law? – IBA Compliance Connection

Are we correct that under the new Illinois unclaimed property law, the presumed abandonment period for a certificate of deposit (CD) begins after the initial renewal date — not allowing for one automatic rollover as under the previous law?

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Yes, you are correct. The new Illinois Revised Uniform Unclaimed Property Act (Illinois RUUPA) calculates the presumed abandonment period for CDs from the “initial date of maturity.” Unlike the previous Illinois unclaimed property law, the Illinois RUUPA does not allow for one automatic CD rollover or renewal before the presumed abandonment period begins to run.

For resources related to our guidance, please see:

  • Illinois RUUPA, 765 ILCS 1026/15-201(6) (“When property presumed abandoned. Subject to Section 15-210, the following property is presumed abandoned if it is unclaimed by the apparent owner during the period specified below: . . . (6) a demand, savings, or time deposit, 3 years after the later of maturity or the date of the last indication of interest in the property by the apparent owner, except for a deposit that is automatically renewable, 3 years after its initial date of maturity unless the apparent owner consented in a record on file with the holder to renewal at or about the time of the renewal; . . .”)