Unclaimed property continues to be a regulatory and operational concern for financial services companies. Complex and constantly-changing legislation often makes compliance with state laws seem like hitting a moving target. This 60-minute webinar will review current legislative and regulatory actions that impact the industry, including the new statutory requirements in Illinois. Additionally, our presenters will share best practices and tactical guidance on how to best comply with the regulations and ensure operational success. Learning Objectives: - Identify new legislation that impacts financial services companies. - Understand the operational impact of unclaimed property compliance on both transfer agents and fund companies. - Learn best practices and tactics to ensure compliance with state unclaimed property.

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Unclaimed Property:
Operational Impact & Best Practices
Wednesday, March 21, 2018

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Today’s Presenters
Debbie Zumoff
Keane
Kim Croston
BNY Mellon
Tara Altman
Keane
Dana Terry
Georgeson
LeeAnn Dionne
DST Systems

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Compare & Contrast
UT TN IL
SB 175 HB 420 SB 9
Effective: 5/9/2017 Effective: 7/1/2017 Effective: 1/1/2018

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Compare & Contrast
Subject UT SB 175 TN HB 420 Illinois SB 9
Securities
Dormancy
A security is presumed abandoned three
years after:
- the date a second consecutive
communication sent by the holder by first-
class United States mail to the apparent
owner is returned to the holder
undelivered by the United States Postal
Service; or
- if the second communication is made
later than thirty (30) days after the first
communication is returned, the date the
first communication is returned
undelivered to the holder by the United
States Postal Service.
**Special outreach provision if owner does
not communicate with holder via US mail
but does so via electronic mail.) (67-4a-
206)
A security is presumed abandoned three
(3) years after:
-the date a second consecutive
communication sent by the holder by first-
class United States mail to the apparent
owner is returned to the holder
undelivered by the United States postal
service; or
-lf the second communication is made
later than thirty (30) days after the first
communication is returned, the date the
first communication is returned
undelivered to the holder by the United
States postal service.
**Special outreach provision if owner does
not communicate with holder via US mail
but does so via electronic mail. (66-29-
111)
A security is presumed abandoned upon
the earlier of the following:
- three (3) years after the date a
communication sent by the holder by first-
class United States mail to the apparent
owner is returned to the holder
undelivered by the United States Postal
Service; however, if such returned
communication is re-sent within one
month to the apparent owner, the 3-year
period does not begin to run until the day
the resent item is returned as
undeliverable; or
- five (5) years after the date of the
apparent owner's last indication of
interest in the security.
**Special outreach provision if owner does
not communicate with holder via US mail
but does so via electronic mail.
***Also a provisions for when an owner is
deceased.) – reportable two (2) years after
date of death (15-208)
Securities Sale &
Liquidation
May sell or otherwise liquidate a security
three (3) years after the administrator
receives the security and gives the
apparent owner notice that the
administrator holds the security. (67-4a-
702(1))
Must sell or otherwise liquidate a security
between eight (8) months and one (1)
year, after receiving the security and
giving the apparent owner notice that the
treasurer holds the security. (66-29-142)
May sell or otherwise liquidate a security
three (3) years after the administrator
receives the security and gives the
apparent owner notice that the
administrator holds the security. Section
15-503. (15-702(a))

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Subject UT SB 175 TN HB 420 Illinois SB 9
Tax Deferred
Retirement Accounts
Tax deferred retirement accounts
presumed abandoned 3 years after the
later of:
- the date a second consecutive
communication sent by the holder
by first-class United States mail to
the apparent owner is returned to
the holder undelivered by the
United States Postal Service; or
- if the second communication is
made later than thirty (30) days after
the first communication is returned,
the date the first communication is
returned undelivered to the holder
by the United States Postal Service.
OR
• The date the owner becomes 70.5
years of age
• If deceased – 2 years after the
holder receives confirmation of
death. (67-4a-202)
* Adds provision for electronic outreach
for owners not receiving first class mail
on at least an annual basis.
Tax deferred retirement accounts
presumed abandoned 3 years after the
later of:
- the date a second consecutive
communication sent by the holder
by first-class United States mail to
the apparent owner is returned to
the holder undelivered by the
United States Postal Service; or
- if the second communication is
made later than thirty (30) days after
the first communication is returned,
the date the first communication is
returned undelivered to the holder
by the United States Postal Service.
OR
• The date the owner becomes 70.5
years of age
• If deceased – 2 years after the
holder receives confirmation of
death. (66-29-106)
* Adds provision for electronic outreach
for owners not receiving first class mail
on at least an annual basis.
Tax deferred retirement accounts
presumed abandoned 3 years after the
later of:
- the date a second consecutive
communication sent by the holder
by first-class United States mail to
the apparent owner is returned to
the holder undelivered by the
United States Postal Service; or
- if the second communication is
made later than thirty (30) days after
the first communication is returned,
the date the first communication is
returned undelivered to the holder
by the United States Postal Service.
OR
• The date the owner becomes 70.5
years of age
• If deceased –1 year after the date of
mandatory distribution following
death. (15-202)
* Adds provision for electronic outreach
for owners not receiving first class mail
on at least an annual basis.

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Subject UT SB 175 TN HB 420 Illinois SB 9
Other Tax-Deferred
Accounts
Presumed abandoned 3 years after
the earlier of:
• The date specified in which
distribution of the property must
begin to avoid a tax penalty: or
• 30 years after the date the
account was opened. (67-4a-203)
*Excludes 529A Plans
Presumed abandoned 3 years after
the earlier of:
• The date specified in which
distribution of the property must
begin to avoid a tax penalty: or
• 30 years after the date the
account was opened. (66-29-107)
* Excludes 529A Plans
Presumed abandoned 3 years after
the earlier of:
• The date specified in which
distribution of the property must
begin to avoid a tax penalty: or
• 30 years after the date the
account was opened.
If owner is deceased – 2 years from
the earlier of:
• The date of the distribution or
attempted distribution of the
property;
• The date of the required
distribution;
• The date specified in which
distribution of the property must
begin in order to avoid a tax
penalty. (15-203)
• Does not exclude 529A Plans

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Subject UT SB 175 TN HB 420 Illinois SB 9
UTMA/UGMA
Accounts
Presumed abandoned 3 years after
the later of:
- the date a second consecutive
communication sent by the
holder by first-class United States
mail to the apparent owner is
returned to the holder
undelivered by the United States
Postal Service;
- if the second communication is
made later than thirty (30) days
after the first communication is
returned, the date the first
communication is returned
undelivered to the holder by the
United States Postal Service;
Or
• The date in which the custodian
is required to transfer the
property to the minor or the
minor’s estate. (67-4a-204)
• * Adds provision for electronic
outreach for owners not receiving
first class mail on at least an
annual basis.
Presumed abandoned 3 years after
the later of:
- the date a second consecutive
communication sent by the
holder by first-class United States
mail to the apparent owner is
returned to the holder
undelivered by the United States
Postal Service;
- if the second communication is
made later than thirty (30) days
after the first communication is
returned, the date the first
communication is returned
undelivered to the holder by the
United States Postal Service;
Or
• The date on which the minor
reaches the statutory age of
majority in accordance with title
35, chapter 7 (66-29-108)
* Adds provision for electronic
outreach for owners not receiving
first class mail communications.
Presumed abandoned 3 years after
the later of:
- the date a second consecutive
communication sent by the
holder by first-class United States
mail to the apparent owner is
returned to the holder
undelivered by the United States
Postal Service;
- if the second communication is
made later than thirty (30) days
after the first communication is
returned, the date the first
communication is returned
undelivered to the holder by the
United States Postal Service;
Or
• The date in which the custodian
is required to transfer the
property to the minor or the
minor’s estate. (15-204)
* Adds provision for electronic
outreach for owners not receiving
first class mail on at least an annual
basis.

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Compare & Contrast
UT SB 175 TN HB 420 IL SB 9 *
Electronic
Contact
Permitted?
Electronic contact by the owner to
serve as an “indication of interest”
which forestalls escheatment
Section 67-4a-208(2)(a)
Electronic contact by the owner to
serve as an “indication of interest”
which forestalls escheatment
Section 66-29-113 (b)(1)
Electronic contact by the owner to
serve as an “indication of interest”
which forestalls escheatment Sections
15-210 (b)(1) and 15-102 (26)

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Compare & Contrast
UT SB 175 TN HB 420 Illinois SB 9
DD Text
New notice header language
required. (67-4a-502(1))
Must state that once turned over, the
owner must file a claim with the
Treasurer and property may be sold by
the administrator. (67-4a-502(b) and
(c))
New notice header language
required. (66-29-129(a))
Must state that once turned over, the
owner must file a claim with the
Treasurer and property may be sold by
the administrator. (66-29-129(b)(2)
and (5))
New notice header language
required. (15-502(a))
Must state that once turned over, the
owner must file a claim with the
Treasurer and property may be sold by
the administrator. (15-502(b)(3) and
(4))
DD Timeframe
Not more than 180 days nor less
than 60 days before filing report.
(67-4a-501(1))
Not more than 180 days nor less
than 60 days before filing report.
(66-29-128 (b))
Not more than 1 year nor less than
60 days prior to filing the report.
(15-501(a))
DD Mail Mode First class mail (67-4a-501(1)) First class mail (66-29-128 (b)(1))
First class mail except securities
valued at or over $1000 must send
letter notice via certified mail. (15-
501 (a)(c))
Electronic Due
Diligence
All three states require both e-delivery and First Class Mail when consent is present.
UT – 67-4a-304
TN – 66-29-128(c)
IL – 15-501(b)

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Subject UT SB 175 TN HB 420 Illinois SB 9
Foreign
Addressed
Property
Substantially similar to Illinois (67-
4a-304)
Substantially similar to Illinois (66-
29-119)
May take custody of property
presumed abandoned, whether
located in this State, another state,
or a foreign country…., and (1)
another state or foreign country is
not entitled to the property because
there is no last-known address of
the apparent owner or other person
entitled to the property in the
records of the holder; or (2) the state
or foreign country of the last-known
address of the apparent owner or
other person entitled to the property
does not provide for custodial taking
of the property. (15-304)

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Enhanced Outreach Requirements
• Email Communication
• Pre-presumption: Illinois,Tennessee and Utah all require special outreach when a
securities owner communicates with the holder electronically and not via US mail.
• Due Diligence: All three states mandate both letter and email notice be sent if
owner has consented to receiving communication via email.
• Certified Mail:
• Illinois Certified Mail required if value of securities is $1000 or more
• Threshold and New Language:
• North Carolina HB 294 – Signed into law on 7/20/17, Effective 10/1/17
• Reduces the due diligence threshold for securities to $25
• Requires specific language be placed into due diligence notice letters.
• Civil penalty added for non-compliance with DD requirement.

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Other Miscellaneous Changes
Arkansas
• HB 1142 (effective 5/9/17):
• Original version required securities sale prior to remittance.
• Amended bill increased the securities dormancy period from five (5) to seven (7) years
and eliminated the sale requirement.
• HB 1752 (effective 7/31/17): amended DD timing to 180/90 days from 120/60 days
Delaware
• SB 13 – Effective 7/1/17
• Adds due diligence requirement
• $50 threshold for all properties except securities
• All amounts for securities
Florida
• Reg 44322 (effective 9/20/17): incorporates reporting manual into regulations which must be
followed when reporting.

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Other Miscellaneous Changes
Iowa
• Reg 2716 (effective 1/1/18): now includes 529 plan accounts similar to RUUPA and more critically
provides that state NOT obligated to indemnify holder if holder failed to comply with DD
requirements.
Ohio
• OH 22096 2017 amended administrative rules to expand the definition of “Owner Generated
Activity”
• Online access via the Holder Website
• If owner is deceased, activity by beneficiary or estate fiduciary is acceptable
• Does not include non-return of mail, holder crediting dividends, account fees, etc.
South Carolina
• SC H 3720 prohibits the use of third-party contingent fee auditors, but it may join a multi-state
contingent fee audit
South Dakota
• SB 34 (effective 9/1/17): requires state treasurer to sell all stocks, bonds, and other negotiable
instruments within 90 days of confirmed receipt, unless the property is the subject of an open claim.
• SB 45 (effective 7/1/18):
• Requires state treasurer to sell all stocks, bonds, and other negotiable instruments within 180 days of
confirmed receipt, unless the property is the subject of an open claim.
• Allows the state 180 days to respond to a claim (increased from 90 days).

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RUUPA States

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Trends
• Inclusion of broader property types
• Electronic outreach
• Life status as a driver
• Increased fines, penalties and interest
• Increased enforcement/audits
• Decreased dormancy periods
• Continued Litigation
• States adopting RUUPA language adding RPO trigger

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Questions & Answers

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Contact Information
Debbie Zumoff
Keane
610.232.0704
dzumoff@KeaneUP.com
Kim Croston
BNY Mellon Asset Servicing
508.871.9222
kimberley.croston@bnymellon.com
Tara Altman
Keane
610.232.0772
taltman@KeaneUP.com
Dana Terry
Georgeson
201.539.1998
dterry@georgeson.com
LeeAnn Dionne
DST Systems, Inc.
617.483.8811
ldionne@dstsystems.com