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Reporting Resources
Request for Comments on Proposed Consolidation of Ownership Codes
Several years ago, a subcommittee of the Uniformity and Standardization Committee, comprised of NAUPA members, holders and other private sector service providers, prepared a proposed consolidated listing of ownership codes to be used in unclaimed property reporting. At that time, the proposed codes were submitted to these same participants and states for comment; however, no further action was taken by the association to adopt or revise the ownership codes.
Currently the Uniformity Committee is revisiting the issue of ownership codes, and is again requesting comments or suggestions. We have extended the comment period to November 30, 2012. Comments may be sent to the association director, David Milby.
BACKGROUND
The mission of the Uniformity and Standardization Committee is to develop and foster uniform practices or procedures related to the administration of state unclaimed property laws and programs. Therefore, back in 2007, the committee created a subcommittee that was charged with determining if consolidation of ownership codes would be possible and if appropriate, how that consolidation could be implemented in the future. The information presented here is the product of earlier drafts that have been improved through comments by members of this subcommittee, the membership of the National Association of Unclaimed Property Administrators (NAUPA) and members of the Unclaimed Property Professionals Organization (UPPO).
CURRENT LANDSCAPE
The current number of ownership codes required by the states for holders to use in reporting unclaimed property is 230. The codes used by unclaimed property agencies will vary from one character to nine characters - they are consistent in most cases - and the states do follow a few (i.e. NAUPA Standard Codes) basic conventions.
ISSUES FOR CONSIDERATION
(1) Should ownership codes that comprise the heaviest use of reporting (i.e. sole owner or payee) be consolidated into one code acceptable by all fifty states and other governmental entities?
(2) If such a change were to take place, would it actually streamline the process for holders in reporting unclaimed property?
(3) Would states and holders be able to convert existing codes already used in current and prior reporting periods?
(4) What effective date would be reasonable to expect the states to accept such a change?
(5) How can the changes be implemented?
CONCLUSION
It has been some time since NAUPA has made recommendations to its members, the holder community and service providers in the reporting process. Taking this into consideration, the current committee endeavored to review the possible benefits of developing this recommendation while considering how the changes could be implemented. Further, would these changes create efficiencies for the holders and identify in broad terms how implementation could take place.
The committee believes that consolidating ownership/relationship codes for the most common types of property reported should be adopted by the states and implementation of these changes can be obtained. Any information and/or comments you could provide will help the committee make an informed recommendation to the NAUPA Executive Committee.
Uniformity & Standardization Committee
Jim McKeon, Unclaimed Property Program Manager, Montana Department of Revenue, Chairman
Bill Dadmun, Policy Analyst, Virginia Treasury
Cindy Hillen, Assistant Director, West Virginia Treasury
Shirley Fowler, Administrator, North Carolina Treasury
Nancy Hollins, Bureau Chief, Holder Operations, California State Controller's Office
Allen Martin, Audit Manager, North Carolina Treasury
Celeste Monahan, Program Manager, Washington Department of Revenue.
Brian Regan, Director, Abandoned Property Division, New Hampshire Treasury
Jack Stollsteimer, Director, Bureau of Unclaimed Property, Pennsylvania Treasury
Jo Ann Tinsley, Claims Manager, West Virginia Treasury
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