Compliance Update Month-by-Month Compliance Obligations

1. Compliance Update Month-by-MonthCompliance Obligations Mark Vogel – Chesapeake Systems

2. Unclaimed property is NOT just a Fall and Spring Process • Don’t let compliance obligations slip through the cracks • Employee turnover can create non-compliance and audit risk

3. JULY (state reports due for MI & TX) • Generate and review Michigan and Texas reports • Start compiling final detail for Fall/November reports from all departments. This covers all outstanding transactions originating June 30, 20XX and prior • Commence the preparation/mailing of all due diligence letters to potential owners, or other necessary notifications, based on the various State statutes

4. AUGUST (state reports due for GU & PR) • Generate and review Preliminary Reports to Guam and Puerto Rico • Due diligence/search letters to be mail out to owners in early August (at the latest) • Begin to track & update owners affirmative due diligence responses • Get approval to attend Chesapeake’s Annual UPCS User’s Conference

5. SEPTEMBER (State reports due for MN & NY) • Generate and review Minnesota and New York reports • Set cut off date for responses resulting from due diligence • Final update of all owners having affirmative responses to due diligence mailing • Affirmative responses after September may be told to contact appropriate State to claim funds • Upon proof, begin to generate payment checks to owners of affirmative response property

6. OCTOBER (Big month. State reports due for many states) • Generate unclaimed property reports in preview mode for review and accuracy (early Oct.) • Upon review, generate reports for signature of Company Officer • Submit/mail (Certified/Overnight/First Class) signed unclaimed property reports to appropriate States (mid-Oct.) • Track receipt & acceptance of all reports • Do any State reporting forms require notarization? • Ensure that applicable State reports and remittance are received by these State’s no later than October 31st. State may allow report to be “postmarked” October 31st.

7. NOVEMBER (Big month. State reports due for many states) • Ensure that applicable State reports and remittance are received by these State’s no later than November 1st. State may allow report to be “postmarked” November 1st. • Finalize affirmative responses from due diligence mailing and issue payment checks • Reconcile all items reported to States or removed during Fall reporting cycle

8. DECEMBER (state reports due for CA,DE, GU, PR) • Generate and mail Final unclaimed property reports to Guam and Puerto Rico by December 10 • LI’s Generate and mail Final unclaimed property reports to California by December 14 • LI’s Generate and mail Final unclaimed property reports to Delaware by December 20 • Consider performing search for funds owed to your company held by States (missingmoney.com) • Send thank you email to all appropriate personnel that assisted with Fall reporting! • If done by yourself, take week off!!

9. JANUARY (no state reports due) • Start compiling final detail for Spring reports from all departments. This covers all outstanding transactions originating December 31, 20XX and prior • Commence the preparation/mailing of all due diligence letters to potential owners, or other necessary notifications, based on the various State statutes

10. FEBRUARY (no state reports due) • All required due diligence letters must be mailed out to property owners (early Feb.) • Begin tracking affirmative responses to due diligence mailings • Generate and review Delaware unclaimed property report • Cut off for owner response to due diligence mailings • Upon proof, begin to generate payment checks to owners of affirmative response property • Do any State reporting forms require notarization? • Sign (by Company Officer) and mail DE report and remittance to State by March 1st

11. MARCH (state reports due for DE, NY, CT) • Delaware report/remittance due March 1 • Generate and review New York applicable unclaimed property reports • Sign (Company Officer) and submit NY report and remittance to State by March 10 • Generate and review Connecticut reports • Sign (Company Officer) and submit CT report and remittance to State by March 31 • Attend annual Unclaimed Property Professional’s Organization (“UPPO”) Conference • Conference for all Holders • Wealth of information and industry contacts

12. APRIL (state reports due for numerous states) • Generate and review Pennsylvania reports • Sign (Company Officer) and submit PA report and remittance to State by April 15 • Generate and review Florida, Illinois, Tennessee & Vermont reports • Sign (Company Officer) and submit FL report and remittance to State no later than April 30th. State may allow report to be “postmarked” April 30th.

13. MAY (Big month. state reports due for numerous states) • Sign (Company Officer) and submit IL, TN & VT reports and remittance to States no later than May 1st. State may allow report to be “postmarked” May 1st. • Finalize affirmative responses from due diligence mailing and issue payment checks • Reconcile all items reported to States or removed during Spring reporting cycle

14. JUNE (state reports due for 1 state – CA) • Should actually be a pretty slow month! • Generate and review Final State Report for California • Send thank you email to all appropriate personnel that assisted with Spring reporting! • If done by yourself, take week off!! • Consider performing internal unclaimed property policies & procedures and past State reports review • Consider performing another search for funds owed to your company held by States (missingmoney.com)