Top Mistakes Businesses Make When Filing Unclaimed Property Claims
Unclaimed property rules are complex and vary by state. Filing mistakes can trigger penalties, interest, and audits. This guide highlights the most common errors—and why partnering with a registered Claimant Designated Representative (CDR) helps you avoid them.
Assuming "we don't have exposure"
Many organizations underestimate exposure across customer credits, vendor refunds, stale checks, and other property types. States have stepped up enforcement; non-compliance can lead to substantial assessments of interest and penalties. [1], [2]
Overlooking property types beyond the obvious
Reporting only one category (e.g., AR credits) while missing others (e.g., payroll, vendor payments, gift certificates) is a frequent cause of non-compliance. Build a property-type inventory and map it to NAUPA codes. [6], [11]
Misapplying dormancy, due-diligence, or priority rules
Dormancy periods and due-diligence thresholds differ by state, and jurisdiction follows the Supreme Court's priority rules (Texas v. New Jersey). Get timing and state right before remitting. [5], [9]
Data quality and formatting errors in reports
Missing owner details, wrong property codes, or file-format errors lead to rejections. Use NAUPA-compatible reporting and state portals to minimize resubmissions. [10], [12]
Treating it as a one-time clean-up instead of a process
Compliance is ongoing: mergers, system changes, and policy drift create fresh liabilities. Establish a recurring review and, when needed, consider a state voluntary disclosure path to resolve historical gaps with reduced penalties. [2], [4], [8]
- State-specific expertise on timing, due diligence, and jurisdiction.
- Process rigor: data validation, NAUPA formatting, accurate remittance.
- Faster resolution and less internal disruption—especially for multi-state operations.
In Georgia, CDRs must register with the Department of Revenue and follow prescribed forms and fee limits. [3], [7], [13]
Next steps for business readers
- Inventory property types across AR, AP, payroll, gift cards, and GL accounts. [6]
- Confirm state-specific dormancy periods, due-diligence thresholds, and reporting windows. [5]
- Validate your data in NAUPA format before submission; test upload in the state portal. [10], [12]
- If you have historical gaps, evaluate a voluntary disclosure option to mitigate penalties. [4], [8]
- Engage a registered CDR to accelerate claims and reduce risk—especially for multi-state filings. [3], [13]
Work with a Registered CDR
Get state-specific guidance, clean data submissions, and fewer surprises. We'll audit your current process and help you file correctly the first time.
Schedule a consultationReferences
- BDO — Top 10 Unclaimed Property Compliance Pitfalls
- Deloitte — Abandoned & Unclaimed Property Insights
- Georgia DOR — Claimant Designated Representative (program overview)
- Washington DOR — Voluntary Disclosure Program (example state)
- Sales Tax Institute — Dormancy & Due Diligence Overview
- Georgeson — Common Causes for Non-Compliance (property types)
- Georgia DOR — CDR FAQs (forms, fee cap, rules)
- Moss Adams — Avoid Penalties; VDA/Amnesty overview
- Wipfli — Priority Rules (Texas v. New Jersey)
- NAUPA — Free Reporting Software & NAUPA File Format
- NAUPA — Reporting Overview & state requirements
- Georgia DOR — Holder Reporting (deadlines & portal)
- Georgia DOR — CDR Purchase Agreement (form)