FAQ's:
HOLDER REPORTING:
- What is Unclaimed Property?
- What is the role of the State related to unclaimed property?
- Who is a holder?
- What are the holder’s reporting obligations?
- How does a holder submit its annual report to Connecticut?
- How can a holder remit payment for their holder report?
- Can a holder send one payment if they have multiple companies to report?
- What is Negative Reporting - nothing to report?
- Do I need a Holder Number assigned before submitting a report?
- What is the date that the unclaimed property report is due to the Office of the Treasurer?
- Is there a late fee or penalty assessed if the report is not filed on time?
- Can a holder request an extension if they cannot file on time?
- Is there a voluntary compliance program for holders with past due reports?
- Can a holder/company use software to generate a report for Connecticut (a NAUPA file)?
- What is the property code to be used for reporting unclaimed property?
- What is the mailing address for unclaimed property holder reports in Connecticut?
- What is the mailing address in the rare event a check must be mailed to the Unclaimed Property Division?
- How should a company handle funds owed to a business, when the original owner no longer exists?
- What are holders’ due diligence requirements in Connecticut?
- What should be included in the due diligence communication?
- Is there a minimum dollar amount for which the due diligence notice is required to be sent to owners?
- Is there a minimum filing amount for a holder to submit a report to Connecticut?
- What is considered a “contact” with an owner in Connecticut?
- Is aggregate reporting allowed in Connecticut?
- What is the proper method or recommended method of reporting unclaimed property to the Office of the Treasurer?
- What is the law regarding expiration dates applied to gift certificates?
- Are Banks subject to the law prohibiting dormancy or inactivity charges, fees, or penalties?
- How should Safe Deposit Box contents be reported to CT's Unclaimed Property Division?
- What does a holder do with Stock Certificates, Savings Bonds, or War/Military/Service Medals found in Safe Deposit Boxes?
- What to do with virtual currency reported to CT’s Unclaimed Property Division?
- What are the guidelines to report and remit Certificates of Deposit (CD) accounts?
- What are the guidelines to report and remit an IRA account?
- Are Health Savings Accounts required to be reported and remitted as unclaimed property?
- Does Connecticut permit early reporting?
- What steps should a holder take to rectify a report submitted incorrectly?
HOLDER REPORTING:
What is Unclaimed Property?
Unclaimed property is a financial asset owned by an individual or entity that must legally be reported and remitted to the State. Property is presumed abandoned and considered “unclaimed” when there has been no owner contact with the property for a set period of time, usually three or more years, depending upon property type.
Unclaimed property includes, but is not limited to, un-cashed checks, bank deposits (savings, checking, Certificates of Deposit (CD’s), etc.), securities, virtual currency, mutual funds, forgotten telephone or utility deposits, insurance benefits and payroll checks. Unclaimed property also consists of the value of the contents of safe deposit boxes, such as tangible property (jewelry, for example), cash, stock certificates and savings bonds.
Real property (such as land, cars, or boats), gift cards, or gift certificates are not returned to the Connecticut Office of the State Treasurer Unclaimed Property Division under Connecticut law.
What is the role of the State related to unclaimed property?
Connecticut law requires holders (such as banks, credit unions, insurance companies, utilities and businesses), to report and remit property that is presumed abandoned under the law annually to the Office of the Treasurer, which safeguards the unclaimed property until the rightful owner comes forward and claims it. The owners then have a single source where they can locate all Connecticut unclaimed property, at CTBiglist.gov.
Who is a holder?
A holder is any person or entity in possession of property that has been presumed abandoned under unclaimed property law and which belongs to another.
What are the holder’s reporting obligations?
All holders, whether located in Connecticut or other states, must report to the State of Connecticut any unclaimed property in their possession that is owed to Connecticut residents. Holders incorporated in Connecticut must also report all “unknown owner” property to Connecticut (generally, holders should remit all unknown property to their state of incorporation).
All holders are responsible for filing reports on behalf of their branches, divisions or affiliates. Other entities including state, county, and city governments, political subdivisions, public authorities, public corporations, estates, trusts or any other legal or commercial entities are also required to report unclaimed property.
If a holder has nothing to report to the State of Connecticut for any given year, the holder must file a Negative Report if it meets the Negative Reporting criteria as described below.
How does a holder submit its annual report to Connecticut?
Holders should submit their annual reports online at www.CTBiglist.gov. Holders should read the Office of the Treasurer’s General Reporting Instructions, which are available under the “Reporting Property tab”; “Holder Forms”. If a holder continues to have questions, they may email the questions to: CTHolderReport@ct.gov.
After filing a report, a holder needs to remit payment to complete its filing. Payment options are described below.
How can a holder remit payment for their holder report?
Holders have several ways to make a payment:
- Online Payment (processed as ACH Debit) – preferred methodology – visit www.CTBiglist.gov to file and pay for holder remittance. Please Note: If there is a debit block on your account please use our Company ID/ACH ID: 3066000798
- ACH Credit – generated directly by holder via their bank
- Wire Transfer– generated directly by holder via their bank
- Check payment, please note this should be used only if one of the electronic payment options is not possible.
Please see the Payment Instructions found under Reporting Property – Holder Forms for further details.
Can a holder send one payment if they have multiple companies to report?
Yes, a holder may send one payment to cover the total if they have multiple companies for which they report. The holder must send remittance to CTHolderReport@ct.gov that provides full detail of the total payment amount and each report (FEIN and individual report total) included in the payment.
What is Negative Reporting - nothing to report?
A Negative Report is a report when there is no unclaimed property to report or remit, essentially a zero-dollar report.
If a holder has a physical location/presence in Connecticut, or is incorporated/based in Connecticut, the holder must file a report every year, even if the business/company has no unclaimed property to submit, in which case a Negative Report should be filed. To do this, please select "Yes" under “This is a Negative Report” question on the report submission page. Please see #4 in our General Reporting Instructions.
Do I need a Holder Number assigned before submitting a report?
No, the Connecticut Office of the Treasurer will assign a holder number to a report upon submission to the office. Numbers are assigned by Federal Tax ID number. NOTE: If the name of the company has changed since the prior year’s report, but the tax ID number did not change, please send correspondence accompanying the holder report that identifies the old name of the company, tax ID number, and the new name of the company.
What is the date that the unclaimed property report is due to the Office of the Treasurer?
Under Connecticut law, unclaimed property holder reports are due to the Office of the Treasurer within 90 days after the presumption of abandonment. Property in Connecticut is presumed abandoned as of December 31st of each year if the conditions for the presumption of abandonment for the property type have been met. The conditions and time frame for a presumption of abandonment for each property category can be found in Connecticut General Statutes Sections 3-56, et seq. Reports not submitted on a timely basis will be considered late and late fees and/or penalties may be levied as directed by state law.
Is there a late fee or penalty assessed if the report is not filed on time?
Per Sec. 3-65b(a) of the Connecticut General Statutes, Holder Reports not submitted on a timely basis are subject to an interest penalty. The penalty can be waived if the Treasurer determines the holder acted in good faith.
Can a holder request an extension if they cannot file on time?
Yes. The company/holder must download and complete the “Extension Request Form” found on our website under Reporting Property – Holder Forms. The form must be submitted to CTHolderReport@ct.gov for approval by the Assistant Treasurer PRIOR to the normal reporting due date. An extension will NOT be granted to companies who failed to complete due diligence requirements, as set forth in state law.
Is there a voluntary compliance program for holders with past due reports?
Connecticut does not have a formal Voluntary Compliance process. The Office of the Treasurer encourages holders to report abandoned property even if the report is past due. Please refer to our “Reporting Property” “Holder Forms” tab for First Time Reporting Instructions. For further questions on overdue reports, please email CTHolderReport@ct.gov.
Can a holder/company use software to generate a report for Connecticut (a NAUPA file)?
Yes. Any unclaimed property software can be used to generate the report file in NAUPA II format; the format curated by the National Association of Unclaimed Property Administrators and accepted by numerous states. The NAUPA report file must be in one of the following file types: .txt, .hrs, or .rpt. There are several private holder reporting software options on the market. Connecticut’s unclaimed property program does accept the free reporting software HRS Pro (basic version, for under 100 properties), which produces a report in NAUPA II standard electronic format, available at: https://hrspro.unclaimedproperty.com. All data in a third-party software (HRS Pro, UPExchange, etc.) is maintained by the holder on their computer, it is NOT automatically transmitted to the state. A report will still need to be submitted on CTBiglist.gov and the holder will upload the NAUPA file generated from the third-party software to our State website.
What is the property code to be used for reporting unclaimed property?
Connecticut utilizes the property codes prescribed by the National Association of Unclaimed Property Administrators (“NAUPA”). Codes used in Connecticut may be found on our website via the link entitled “Property Codes with Dormancy Periods” under Holder Forms.
What is the mailing address for unclaimed property holder reports in Connecticut?
All reports should be submitted on our website at https://ctbiglist.gov/app/submit-a-report. The Office of the Treasurer does not accept physical reports.
What is the mailing address in the rare event a check must be mailed to the Unclaimed Property Division?
In the rare event a holder must submit a physical check it must be mailed to the Bank lockbox address listed below. Please refer to our website under the “Reporting Property” “Holder Forms” tab for General Reporting Instructions or Payment Instructions for more reporting information. NOTE: The below address is a Bank Lockbox NOT a traditional post office box:
State of Connecticut Office of the Treasurer
Unclaimed Property Division
PO Box 150435
Hartford, CT 06115-0435
The Bank Lockbox accepts certified and overnight deliveries.
How should a company handle funds owed to a business, when the original owner no longer exists?
When, in the process of performing due diligence, a holder determines the assets can no longer be returned to the original business owner because: 1) the original owner cannot be found; 2) the original owner is no longer a legal entity; or 3) the original owner information is otherwise insufficient, the property must still be reported. If no owner details are known, it may have to be reported as “Unknown”. The property would be presumed abandoned as of the current year. The holder should remit the property to the State Treasurer’s Office in accordance with the dormancy periods and reporting requirements stipulated by state laws.
What are holders’ due diligence requirements in Connecticut?
NOTICE TO ALL HOLDERS: Changes to Connecticut Conn. Gen. Stat. Sec. 3-65a, effective July 1, 2024, impact holder due diligence requirements relating to the content and delivery methods of these communications. Please review this statute carefully to ensure compliance with the current requirements.
Connecticut law requires holders to notify owners, via due diligence notices, before a presumption of abandonment is to take effect with respect to their property. Such due diligence notice must be sent to owners by first class mail directed to the owner’s last-known address and, if a holder has received consent to the electronic delivery of any notices required by law, by electronic mail directed to the owner’s last-known electronic mail address. State statutes indicate that due diligence notices must be sent not less than one year before presumption of abandonment is to take effect (except for those properties with a one-year dormancy period, in which case due diligence letters must be sent in the manner described above not less than 180 days before a presumption of abandonment is to take effect). Due diligence is to be performed on all properties irrespective of dollar amount.
We encourage holders to send their due diligence notice at a time that allows owners sufficient time to respond prior to the presumption of abandonment. Note: Do not send due diligence communications January 1st thru March 31st for property that was presumed abandoned as of December 31st in the prior year. Sending due diligence communications after the statutory presumption of abandonment does not comply with Connecticut’s due diligence laws.
What should be included in the due diligence communication?
The letter and email should:
- Notify the owner that evidence of interest in the property must be indicated or the property at issue will be transferred to the Treasurer and subject to remittance to the State.
- If the property at issue is a security, virtual currency, or tangible property from a safe deposit box, a holder must notify the owner that such property may be liquidated either prior to or following its reporting to the Treasurer, and they will be entitled only to the proceeds of that liquidation.
The precise requirements for due diligence communications can be found in Connecticut General Statute Sec. 3-65a and a holder is responsible for being familiar and complying with that law.
Is there a minimum dollar amount for which the due diligence notice is required to be sent to owners?
No. The Connecticut statutes do not set a minimum value for sending a due diligence notice to an owner. Due diligence is to be performed on all properties irrespective of dollar amount.
Is there a minimum filing amount for a holder to submit a report to Connecticut?
No, there is NO minimum filing amount in Connecticut. All dollar amounts should be reported to the Connecticut Office of the Treasurer.
What is considered a “contact” with an owner in Connecticut?
Due diligence notices are sent out by the holder as required by statute, via first class mail to the owner’s last known address and by electronic mail (email) if a holder has received an owner's consent for the electronic delivery of any notices required by law. If the owner contacts the holder via phone conversation, email, letter, or in person, this is considered contact and the property should not be presumed abandoned. If the due diligence letter is returned by the post office as undeliverable, this is not “contact” with the owner and the property is subject to reporting and remittance by the holder. If an owner has several accounts within the same holder, they should be linked so that contact on one account is considered contact on all accounts. If a 1099 form is sent out for proceeds on a stock transaction and the 1099 is not returned by the post office, we consider this contact with the owner; if the 1099 is returned by the post office, the holder should consider this an indication of having lost contact with the property owner.
Is aggregate reporting allowed in Connecticut?
No. At this time aggregate reporting is not allowed in Connecticut. All amounts, regardless of the size, should be reported to the Connecticut Office of the Treasurer with detailed owner information on the holder report. If a holder has submitted a holder report with an aggregate amount in the past, the holder is required to retain the records for 20 years as instructed by Sec. 3-65a (h) of the Connecticut General Statutes. Holders may file “unknown owners” on a holder report if the owner name and other details are not known.
What is the proper method or recommended method of reporting unclaimed property to the Office of the Treasurer?
Please submit all reports using our website – physical reports are no longer accepted. Please refer to our General Reporting Instructions for guidelines.
What is the law regarding expiration dates applied to gift certificates?
Gift cards/gift certificates are not considered a type of unclaimed property subject to reporting and remittance under Connecticut law, no matter any dormancy period. Connecticut state law concerning expiration dates, and dormancy or inactivity fees, has not changed: both expiration dates and dormancy fees are prohibited on gift certificates and gift cards sold in Connecticut.
Are Banks subject to the law prohibiting dormancy or inactivity charges, fees, or penalties?
Yes. Financial institutions may not impose any charges or fees with respect to abandoned property under Section 3-65c. Lawful charges that banks may apply are stipulated by regulatory authorities within the Connecticut Department of Banking.
How should Safe Deposit Box contents be reported to CT's Unclaimed Property Division?
Holders should be aware of Sections 3-65a(i) and 3-57a(a)(5) of the Connecticut General Statutes. Unclaimed property includes any funds or other personal property in a safe deposit box on which the lease or rental period has expired which have been unclaimed by the owner for more than five years from the date on which the lease or rental period expired. Physical contents of safe deposit boxes must be liquidated or sold at auction, and only net cash proceeds in the owner’s name should be reported. The date for reporting follows the same deadline as all other unclaimed property – presumption of abandonment as of December 31st and the report is to be submitted within 90 days after that. Holders shall complete the sale of such property and deliver the net cash proceeds to the Office of the Treasurer Unclaimed Property Division within thirty days after filing the report.
What does a holder do with Stock Certificates, Savings Bonds, or War/Military/Service Medals found in Safe Deposit Boxes?
As per instructions on the Safe Deposit Box Contents and Proceeds document under the “Reporting Property” “Holder Forms” tab, the following process applies:
Stock Certificates, listed in the owner(s) names, may be sent to the Office of the Treasurer and we will maintain them as safekeeping items. These stock certificates should NOT be included on the regular holder report. The Original Stock Certificate(s) must be sent to the Office of the State Treasurer along with a separate excel spreadsheet that should include: box ownership information, owner(s) name and address on the stock certificate(s), and stock certificate details such as stock company name, number of shares, CUSIP, etc.
U.S. Savings Bonds should be sent directly to the US Department of the Treasury, Bureau of the Public Debt. U.S. Savings Bonds are NOT to be included on the holder report.
Connecticut law provides that War/Military/Service Medals should NOT be sold and are not to be included on the holder report. They should be sent directly to the Department of Veteran’s Affairs as listed below, and reported as a safekeeping item to the Connecticut Office of the Treasurer on a separate excel spreadsheet that includes: box ownership information, name, address, and any other available details. If possible, a picture of the medal should be sent with the spreadsheet listing the ownership details. The original medals and a copy of the spreadsheet must be sent to the: State of Connecticut, Department of Veteran's Affairs, General Counsel and Director of Legislative Affairs, 287 West Street, Rocky Hill, CT 06067.
What to do with virtual currency reported to CT’s Unclaimed Property Division?
Pursuant to Connecticut General Statute Section 3-65a(i), holders must liquidate virtual currency and deliver the net proceeds to the Office of the Treasurer Unclaimed Property Division within thirty days after filing the report.
What are the guidelines to report and remit Certificates of Deposit (CD) accounts?
Certificates of Deposit are considered unclaimed after 3 years of dormancy. Owners are normally mailed a notice from the bank to indicate the CD will automatically renew unless the bank hears from the owner. If the owner does not respond to the notice, the CD automatically renews. Sometimes if the notice is returned to the holder by the Post Office, the CD has already renewed. At this point the bank is encouraged to flag the account because mail was returned by the Post Office and contact was lost. This should also prevent the CD from renewing again. If return mail is received prior to the renewal of the CD, the bank should not renew the CD, but note the account as dormant allowing the 3 year dormancy period to toll and the property should be remitted to the state unless the owner contacts the Bank.
At the end of each calendar year, a 1099 is issued to the owner for the interest accrued during the year if appropriate. If the 1099 is returned by the Post Office as undeliverable, the holder assumes contact is lost and documents such in the account and the CD does not renew. Once the dormancy period has been met and the CD has matured, the property must be remitted to the Treasurer's Unclaimed Property Division.
What are the guidelines to report and remit an IRA account?
To report and remit funds in an IRA account, the financial institution must be certain the owner(s) of the account has reached the Required Minimum Distributions (RMD) age, as defined by the Internal Revenue Service. Under Connecticut law, IRA accounts are considered abandoned as of the IRS – RMD date plus a waiting period of an additional 6 months. Then, the 3-year dormancy period begins, with due diligence to be conducted during the last year of dormancy. With recent IRS changes to the RMD ages, commencement of the dormancy period may vary.
If an IRA account owner’s 70th birthday was prior to July 1, 2019, then they are not required to take a minimum distribution until they have reached the age of 70 ½. Therefore, with the waiting and dormancy periods, the owner(s) must reach the age of 74 before the property is to be reported and remitted to the State.
If an IRA account owner’s 70th birthday was between July 1, 2019, and December 31, 2020, then they are not required to take a minimum distribution until they have reached the age of 72. Therefore, with the waiting dormancy periods, the owner(s) must reach the age of 75 1/2 before the property is to be reported and remitted to the State.
If an IRA account owner’s 70th birthday was after December 31, 2020, then they are not required to take a minimum distribution until they have reached the age of 73. Therefore, with the waiting dormancy periods, the owner(s) must reach the age of 76 1/2 before the property is to be reported and remitted to the State.
However, if the financial institution knows that the owner is deceased, and the beneficiaries or heirs cannot be located, the holder can waive the 3-year dormancy period, and reported and remitted the property to the State. The owner’s date of death should be included on the property when it is reported and remitted.
Note: At this time, Roth IRA's do not have an end date or mandatory distribution date (trigger dates); therefore, Roth IRA's do not escheat to Connecticut unless the financial institution knows the owner(s) is deceased and the beneficiaries or heirs cannot be located.
Are Health Savings Accounts required to be reported and remitted as unclaimed property?
Generally, a Health Savings Account (HSA) is a tax-exempt custodial account, or a trust, set up with a qualified HSA trustee to pay or reimburse certain medical expenses. HSAs may also be set up with mandatory distribution dates under IRS rules. Contributions to HSAs remain in the account until they are used by its owner.
Holders must determine the type of Health Savings Account created, review the terms of the plan or trust agreement, and then determine the dormancy period. For example, does the HSA have a mandatory distribution date? If so, what is the mandatory distribution date? In this example, the dormancy period may be 3 years plus 6 months after the mandatory distribution date. Or was the HSA set up as a trust account? If so, what does the plan or trust agreement state regarding distribution? In this type of account, the dormancy period may be 7 years because the funds are held in a fiduciary capacity.
Based on the complexity of these accounts Connecticut has not yet adopted the NAUPA codes for Health Savings Accounts.
Does Connecticut permit early reporting?
No, Connecticut does not allow early reporting. However, should you have specific issues or unique circumstances please email to CTHolderReport@ct.gov.
What steps should a holder take to rectify a report submitted incorrectly?
Holders that submit a report incorrectly must: (1) send an email to CTHolderReport@ct.gov including company name, FEIN number, reported amount and a brief explanation of the error. (2) Wait for a response and direction from the Unclaimed Property Division.
Revised: June 2024