How should we handle unclaimed property reporting for items that are in a safe deposit box that haven’t been claimed but are owned by an active military individual (according to the Department of Defense’s website)?

Under the Illinois Revised Uniform Unclaimed Property Act (Illinois RUUPA), property held in a safe deposit box is considered unclaimed property five years after the expiration of the lease or rental period for the box. There are no exceptions for active duty military personnel. If a safe deposit box holder has not made any qualifying indications of interest in the property (or in other property sharing the same mailing address on your books and records), it must be reported to the Illinois Treasurer as unclaimed property.

For resources related to our guidance, please see:

  • 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 1026/15-210(a) (“The period after which property is presumed abandoned is measured from the later of: (1) the date the property is presumed abandoned under this Article; or (2) the latest indication of interest by the apparent owner in the property.”)
  • 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:

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

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;

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

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

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.”)