Regarding the unclaimed property rules for certificates of deposit (CDs), if we have not had contact with a customer for over three years, but the CD does not mature until next year or later, should it be escheated to the state?

No, a CD should not be reported as unclaimed property until three years of inactivity have passed since the initial date of maturity for the CD.

Under the Illinois Revised Uniform Unclaimed Property Act (Illinois RUUPA), a CD is considered abandoned “3 years after its initial date of maturity” or the date of the last indication of interest in the CD by the apparent owner. A CD that has not yet matured would not be presumed abandoned until three years of inactivity have passed after the initial maturity date (or the most recent indication of interest in the account, if later).

For resources related to our guidance, please see:

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