No, we are not aware of any requirement to notify your customers regarding the shortened presumed abandonment periods for bank deposit accounts under the Illinois Revised Uniform Unclaimed Property Act (Illinois RUUPA).

Of course, it would be prudent to attempt to notify your customers before your bank turns over property that is presumed abandoned to the State Treasurer. Such notices may stave off customer dissatisfaction over the shortened abandonment periods while also providing added value to customers who are unaware of the Illinois RUUPA’s changes, particularly your business customers who may have their own unclaimed property reporting responsibilities.

Note that many types of property are subject to presumed abandonment periods that can be longer than three years, such as retirement accounts and property held in safe deposit boxes. Check out our IBA Unclaimed Property Comparison Chart, which addresses the property types covered by the new law, together with their presumed abandonment periods and start dates for measuring inactivity.

For resources related to our guidance, please see:

• Illinois RUUPA, 765 ILCS 1026/15-501(a) (“Subject to subsections (b) and (c), the holder of property presumed abandoned shall send to the apparent owner notice by first-class United States mail that complies with Section 15-502 in a format acceptable to the administrator not more than one year nor less than 60 days before filing the report under Section 15-401 if: . . . .”)

• Illinois RUUPA, 765 ILCS 1026/15-201(2) (“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: . . .”)

• Illinois RUUPA, 765 ILCS 1026/15-205 (“Tangible property held in a safe-deposit box are presumed abandoned if the property remains unclaimed by the apparent owner 5 years after the expiration of the lease or rental period for the box.”)

• Illinois RUUPA, 765 ILCS 1026/15-202(a) (“When tax-deferred retirement account presumed abandoned. . . . (a) Subject to Section 15-210, property held in a pension account or retirement account that qualifies for tax deferral under the income-tax laws of the United States is presumed abandoned if it is unclaimed by the apparent owner after the later of: . . .”)