While we caution that we are not experts in the unclaimed property laws of states outside of Illinois, we recommend filing negative reports (i.e., filing an unclaimed property report even when you have no property to report) when required by a particular state’s law. For example, we believe that Wisconsin requires financial institutions with a physical presence in the state to file negative reports, while Iowa does not require negative reports. Although the Illinois Treasurer may have reciprocal agreements with those states to provide for the transfer of property to those states, we do not believe that such reciprocal agreements would cover the obligation to file negative reports.

For resources related to our guidance, please see:

• Wisconsin Department of Revenue, Unclaimed Property Holder Report Guide, Publication 82 (09/21) (“Financial institutions, utility companies, and life insurance companies, with a physical presence in Wisconsin, must file a holder report even if no unclaimed property is reported (also known as a negative report).”)

• Iowa State Treasurer, Frequently Asked Questions (“Does Iowa require negative reporting? No. If you are not holding any reportable property at this time, you do not need to file a report.”)