Are there Minimum Amounts for Filing Unclaimed Property Reports?by Tracey Reid on 10/22/12
It is REPORTING TIME AGAIN! If you are like me, you are busy creating, proof-reading and getting Unclaimed Property reports signed for the upcoming Fall filing deadlines. As you sort through all of those unclaimed items this fall, it can be frustrating to think you have to file a report for every little check or credit on your books, especially if you only have 1 item to report to any particular state. I got a question today from someone with just such a dilemma and I know it is not a unique problem, so I thought I would share
QUESTION: We have a lot of really small checks ($1.00 or less) that are due to several different states. It's such a hassle! Is there a minimum that should be reported? If there is, is each state a different amount?
No, there is no minimum amount that must be reported as unclaimed property. There are some administrative quirks that might help you with the administrative burden of filing multiple reports, though!
First, every state has an "aggregation" minimum, which allows you to lump all of the small sums of money that are equal to or less than their aggregation amount (usually between $25 and $50) into line item on the report. There are a few states with $100 aggregate amounts, but there are also a couple of states (i.e., Puerto Rico with $1.00 and New York with $20.00) that are smaller, so check each state of last known address to be sure. They also do not require due diligence letters to be sent out for items worth less than their aggregation amount.
Second, some states will accept de minimus amount of property that are technically reportable to other states, and agree to forward the amounts to the correct states through their super-secret intra-state network, if you report the small dollar amount items on your regular report (Pennsylvania has always done this, for example).
Third, some state, like South Carolina, do not want you to file a report until you have a minimum amount due to them (SC'S amount is $250). They still expect you to maintain the unclaimed property and to report it when you reach a minimum amount, but you don't have to send in a report for very small dollars, unless you want to. You are not forbidden from filing small dollar reports....you are just discouraged.
I hope this helps! Now, back to the grindstone....