Delaware Adopts Some Unclaimed Property Task Force Recommendations
At the start of the year, we noted that the Delaware Unclaimed Property Task Force issued a report suggesting certain reforms to the state’s unclaimed property practices and procedures. Unfortunately, many of the high-profile recommendations (e.g., limiting lookback periods, implementing a new VDA program, implementing a statute of limitations) did not make it through the legislative process. Instead, the Delaware legislature recently passed Senate Bill 11 (as amended) which implements some far more modest changes to the state’s rules. In particular, the new law provides that the Department of Finance can not give more than 50% of its outside audits to the same auditing Firm, sets forth a 2 year “cooling off” period before former unclaimed property staff can join auditing firms, and makes some minor changes to the state’s administrative appeal process.
While these are all positive developments, they likely fall short of what the holder community was looking for.