Yes, we believe that both processes described in your question continue to be necessary under the Illinois Revised Uniform Unclaimed Property Act (Illinois RUUPA).

When a customer dies, their accounts generally will be presumed abandoned two years after their last indication of interest in the accounts (unless the applicable abandonment period is shorter than two years). For tax-deferred retirement accounts and securities, if your bank receives notice of the owner’s death in the ordinary course of business, you must attempt to confirm the death within ninety days of receiving the notice. For these reasons, we recommend continuing to review any lists of deceased customers — first, to check for reportable unclaimed property and second, to ensure that you have met the requirement to confirm the deaths of any retirement account or securities customers.

Note that a new account owner could come forward and indicate an interest in the property, preventing it from being presumed abandoned.

For minor custodial accounts established under the Uniform Transfers to Minors Act (UTMA), the presumed abandonment period begins to run when the minor reaches the age of majority — which could be age 18 or 21, depending on the type of UTMA account. Consequently, we recommend reviewing all UTMA accounts for which the minor has reached the age of majority for any indication of interest and the removal of the former custodian.

For resources related to our guidance, please see:

• Illinois RUUPA, 765 ILCS 1026/15-201 (“Notwithstanding anything to the contrary in this Section 15-201, and subject to Section 15-210, a deceased owner cannot indicate interest in his or her property. If the owner is deceased and the abandonment period for the owner’s property specified in this Section 15-201 is greater than 2 years, then the property, other than an amount owed by an insurance company on a life or endowment insurance policy or an annuity contract that has matured or terminated, shall instead be presumed abandoned 2 years from the date of the owner’s last indication of interest in the property.”)

• Illinois RUUPA, 765 ILCS 1026/15-202(b) (tax-deferred retirement accounts) (“If a holder in the ordinary course of its business receives notice or an indication of the death of an apparent owner and subsection (a)(2) applies, the holder shall attempt not later than 90 days after receipt of the notice or indication to confirm whether the apparent owner is deceased.”)

• Illinois RUUPA, 765 ILCS 1026/15-208(d) (securities) (“If a holder in the ordinary course of its business receives notice or an indication of the death of an apparent owner, the holder shall attempt not later than 90 days after receipt of the notice or indication to confirm whether the apparent owner is deceased. Notwithstanding the standards set forth in paragraphs (a), (b) and (c), if the holder either receives confirmation of the death of the apparent owner in the ordinary course of its business or confirms the death of the apparent owner under this subsection (d), then, the property shall be presumed abandoned 2 years after the date of death of the owner.”)

• Illinois RUUPA, 765 ILCS 1026/15-102(21) (“‘Owner’, unless the context otherwise requires, means a person that has a legal, beneficial, or equitable interest in property subject to this Act or the person’s legal representative when acting on behalf of the owner. The term includes: . . . (B) a beneficiary, for a trust other than a deposit in trust; . . .”)

• Illinois RUUPA Administrative Rules, 74 Ill. Adm. Code 760.290(e), Deceased Owner (“Sections 15-202 and 15-208 of the Act both provide that when a holder, in the ordinary course of its business, receives notice or an indication of the death of an apparent owner, the holder shall attempt not later than 90 days after receipt of the notice or indication to confirm whether the apparent owner is deceased. 1) These provisions are not intended to require a holder to independently confirm the death of the apparent owner when the holder reasonably believes that the apparent owner is deceased. 2) Instead, these provisions establish a 90-day deadline for a holder to conduct any independent investigation or search to confirm the death of the apparent owner. 3) EXAMPLE: If a holder learns that an apparent owner is listed on the Social Security Administration's Death Master File (DMF) and the holder is satisfied that the presumption of death from such a match is correct, then the holder does not need to independently confirm the death of the apparent owner.”)

• Illinois RUUPA Administrative Rules, 74 Ill. Adm. Code 760.290(a), Deceased Owner (“(1) Apparent owner interest shall include the activity of beneficiaries and estate executors or other persons who have a legal or equitable right to ownership or custody of the property when the apparent owner as listed in the records of the holder is deceased. (2) Thus, while a deceased apparent owner can no longer indicate interest in their own property, the new owner or his/her agent(s) may indicate interest in the property and, thus, prevent abandonment.”)

• Illinois RUUPA, 765 ILCS 1026/15-204(a) (Property held in an UTMA account “is presumed abandoned if it is unclaimed by or on behalf of the minor on whose behalf the account was opened 3 years after the later of:

(1) except as in subparagraph (2), the a communication sent by the holder by first-class United States mail to the custodian of the minor is returned undelivered to the holder by the United States Postal Service;

(2) if is re-sent within 30 days after the date the first communication is returned undelivered, the date the second communication was returned undelivered; or

(3) the date on which the custodian is required to transfer the property to the minor or the minor’s estate .”)

• Illinois RUUPA Administrative Rules, 74 Ill. Adm. Code 760.290(e), Deceased Owner