Yes, we believe that activity on a safe deposit box would constitute activity on the CD sharing the same “apparent owner” and mailing address at your bank.

The Illinois Revised Uniform Unclaimed Property Act (Illinois RUUPA) provides that activity “in any other account” at your institution counts as activity on an account to which Section 201(6) applies — that is, a demand, savings or time deposit. In this scenario, a time deposit (the CD) might be inactive, but activity on another account — the safe deposit box — would count as activity on the CD. For example, payments made to the bank pursuant to a safe deposit box agreement would constitute an indication of interest in the CD (unless the payments are made by a previously authorized recurring ACH transfer).

For resources related to our guidance, please see:

• Illinois RUUPA, 765 ILCS 1026/15-210(f) (“If the apparent owner has another property with the holder to which Section 201(6) applies, then 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:

(A) the apparent owner engages in one or more of the following activities:

(i) the apparent owner undertakes one or more of the actions described in subsection (b) of this Section regarding any account that appears on a consolidated statement with the inactive account;

(ii) the apparent owner increases or decreases the amount of funds in any other account the apparent owner has with the financial organization; or

(iii) the apparent owner engages in any other relationship with the financial organization, including payment of any amounts due on a loan; and

(B) the foregoing apply so long as the mailing address for the apparent owner in the financial organization’s books and records is the same for both the inactive account and the active account.”)

• 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; . . .”)

• Illinois RUUPA, 765 ILCS 1026/15-210(b) (“Under this Act, an indication of an apparent owner’s interest in property includes: . . . (5) a deposit into or withdrawal from an account at a financial organization, except for a recurring Automated Clearing House (ACH) debit or credit previously authorized by the apparent owner or an automatic reinvestment of dividends or interest; . . .”)