We recommend delaying the reporting and delivery of the CD until the next reporting date after it matures in 2022, as permitted under the Illinois Revised Uniform Unclaimed Property Act (Illinois RUUPA).

Under the Illinois RUUPA, an automatically-renewable CD is presumed abandoned three years after the most recent indication of interest “following the completion of the initial term of the time deposit and one automatic renewal term of the time deposit.” Here, it appears that the CD has already completed its initial term and one automatic renewal term, which would have ended in 2010. Consequently, if there have been no indications of interest in the CD in the last three years, it is reportable as unclaimed property.

However, the Illinois RUUPA states that automatically-renewable time deposits do not need to be reported and delivered to the Treasurer when doing so would cause the owner to pay a penalty or forfeit interest (such as paying an early-withdrawal penalty on a renewable CD). Instead, you may delay reporting and delivering the CD to the Treasurer until a penalty or forfeiture would no longer result from delivery of the property to the Treasurer.

Once the CD matures in 2022, you would report and deliver the property on your next applicable reporting date (which would be November 1 for a bank) and indicate in your report that “the property is being reported on an extended date pursuant to” Section 15-603(b) of the Illinois RUUPA.

For resources related to our guidance, please see:

• Illinois RUUPA, 765 ILCS 1026/15-201 (“Subject to Section 15-210, the following property is presumed abandoned if it is unclaimed by the apparent owner during the period specified below: . . . (iv) an automatically renewable time deposit for which the owner consented to the automatic renewal in a record on file with the holder, 3 years after the date of last indication of interest in the property by the apparent owner, following the completion of the initial term of the time deposit and one automatic renewal term of the time deposit; . . .”)

• Illinois RUUPA, 765 ILCS 1026/15-603(b) (“If property in a report under Section 15-401 is an automatically renewable time deposit and the holder determines that a penalty or forfeiture in the payment of interest would result from paying the deposit to the administrator at the time of the report, the date for reporting and delivering the property to the administrator is extended until a penalty or forfeiture no longer would result from delivery of the property to the administrator. The holder shall report and deliver the property on the next regular date prescribed for reporting by the holder under this Act after this extended date, and the holder shall indicate in its report to the administrator that the property is being reported on an extended date pursuant to this subsection (b).”)