This page addresses key areas of interest regarding Tennessee unclaimed property and escheatment laws and regulations.
The deadline for annual reporting and remittance in Tennessee has moved to October 31 for all holders beginning in 2019 (per the website, Tennessee accepts reports on November 1). Early reporting is permitted provided that all due diligence efforts are complete.
All holders have an obligation to report abandoned or unclaimed property to the state in order to maintain compliance with Tennessee’s unclaimed property laws and regulations. Holders reporting to Tennessee are required to submit their reports electronically through the “REPORT IT TN” web application found on the state’s website. Paper reports are not accepted.
Tennessee requires holders to send due diligence notifications for any property with a value of $50 or more. Due diligence letters must be sent via first class mail each reporting cycle to the apparent owner at the last known address not more than 180 days or less than 60 days from the reporting deadline.
The due diligence notice must inform the owner that the holder is in possession of unclaimed property that will be turned over to the state unless the owner claims it from the holder before the report is filed. Tennessee has additional language that must be included in the due diligence notifications.
Most property types in Tennessee have a dormancy period of three years. For most property types, accounts are considered dormant if the owner of a property has not indicated any interest in the property or if no contact has been made for the allotted dormancy period for that property.
Reporting unclaimed property in Tennessee, and other jurisdictions, can be a stressful process that consumes valuable internal resources. However, when properly managed, the annual reporting and escheatment process does not need to be a burdensome experience.
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