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@Regulatory: May 2007

Financial Foresight is a publication providing analysis about trends and issues important to senior- and middle-management executives at financial
services companies.


Financial Services

Financial Foresight
Unclaimed Property Compliance for Financial Services Companies

Unclaimed property is often overlooked as an area of risk for many financial services companies. According to industry estimates, states are holding more than $22 billion in unclaimed intangible assets and fewer than 20 percent of all companies are estimated to be in compliance with state unclaimed property laws.

“Lack of compliance can have serious regulatory consequences for banks, asset managers, insurance companies, and securities firms,” says Kevin M. McGovern, National Partner-in-Charge of Financial Services Regulatory Consulting for Deloitte & Touche LLP. “With limited exception, there is no statute of limitations on an unclaimed property liability, and non-compliance can have Sarbanes-Oxley implications as well.”

To mitigate potential areas of risk, financial services companies need to develop and implement effective policies and procedures for identifying unclaimed property and taking appropriate steps to return such property to its rightful owners and/or report it to the appropriate state.

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