colorado unclaimed property reporting guide 2010

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August 2010 Colorado Unclaimed Property Reporting A Guide for Financial Institutions If you would like assistance in interpreting, implementing, applying, or reviewing your compliance with this rule, please call us at 888-WE-CMPLY (888-932-6759) or e-mail us at [email protected] . Please be an ethical and responsible user of this copyright-protected work. Your recognition of and respect for the effort and expense required to produce it is greatly appreciated.

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Page 1: Colorado Unclaimed Property Reporting Guide 2010

August 2010

Colorado Unclaimed Property Reporting A Guide for Financial Institutions

If you would like assistance in interpreting,

implementing, applying, or reviewing your compliance

with this rule, please call us at

888-WE-CMPLY (888-932-6759)

or e-mail us at [email protected].

Please be an ethical and responsible user of this copyright-protected work.

Your recognition of and respect for the effort and expense required

to produce it is greatly appreciated.

Page 2: Colorado Unclaimed Property Reporting Guide 2010

Colorado Unclaimed Property Reporting August 2010

© 2010 Compliance Info, LLC www.mycomplianceinfo.com Page 2 of 18

Contents Identifying Unclaimed Property .............................................................................................................. 3

Who Must Report Unclaimed Property? .......................................................................................... 4 When Must We File Our Report? ..................................................................................................... 4 How May We File Our Report? ......................................................................................................... 4 What if We Don’t File? ..................................................................................................................... 5

Notice Requirements .............................................................................................................................. 5 What are the notice requirements? ................................................................................................. 5 What Must the Notice Say? ............................................................................................................. 6 What if A Notice is Returned as Undeliverable? ............................................................................... 6 How Far Must We Go in Trying to Find the Owner?.......................................................................... 6 Can We Assess Dormancy or Inactivity Fees or Stop Paying Interest on Unclaimed Property? .......... 7

Special Rules for Specific Property Types ................................................................................................ 7 Securities ......................................................................................................................................... 7 Safekeeping Items ........................................................................................................................... 7 Safe Deposit Box Contents ............................................................................................................... 7

Allowable Deductions ............................................................................................................................. 8 Can the Remittance be Offset by Amounts Owed to the Holder? ..................................................... 8 What if the value of the property is less than $25? .......................................................................... 9

Completing the Forms ............................................................................................................................. 9 Form A: Transmittal Form ............................................................................................................... 9 Form B: Report of Unclaimed Property ......................................................................................... 10

Avoiding Common Errors. ...................................................................................................................... 10 Recordkeeping ...................................................................................................................................... 11 Reactivation, Reimbursements and Refunds . ........................................................................................ 11

What if the Owner Contacts Us Before We File? ............................................................................ 11 What if An Owner Wants to Claim Property After Funds Have Been Remitted? .............................. 12 What if We Remitted too Much? ................................................................................................... 12

Tips for an Effective Program ................................................................................................................. 13 Exhibit A: Property Code/Description, Deduction Code and Dormancy Periods ...................................... 14 Exhibit B: Special Rules for Delivering Securities to the Colorado State Treasurer .................................. 17

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Colorado Unclaimed Property Reporting August 2010

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Any holder of unclaimed property must report it to the Colorado State Treasurer annually. Along with the report, a holder must turn over (or “remit”) the property to the State. This requirement to turn over unclaimed property to a State authority exists in all fifty states. It is sometimes referred to as “escheat.”

The annual reporting and remittance deadline is May 1st for life insurance companies and November 1st for all other holders.

What is Unclaimed Property?

“Unclaimed property” is property that is presumed abandoned because it has had no activity for a specified period of time. It is defined in Section 38, Article 13 of the Colorado Revised Statutes. The statute distinguishes between “tangible” and “intangible” property. Generally, tangible property is personal property that you can see or touch, like jewelry, artwork, or a coin collection. Examples of intangible property include:

Banks/Credit Unions

Checking or savings account balances

Checks or drafts that were not cashed (cashier’s checks, money orders, traveler’s checks)

Credit balances or customer overpayments on loans, credit cards or other accounts

Items held as collateral and/or in safekeeping

Moneys distributable from trusts

Safe deposit box contents Securities, Insurance and Investments

Stocks, bonds and mutual funds, and any uncashed dividends

Proceeds from annuities, insurance policies, endowments

Insurance claims payments or premium refunds that were not cashed

Items held in safekeeping

Moneys distributable from trusts Employment-Related Items

Wages and payroll that were not cashed or received Property is considered abandoned after it has had no activity for a specified period of time. This period of time, called the dormancy period, varies depending upon the property type.

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Small Business Exception: If a business has gross annual receipts less than $500,000, annual reporting is not required until

aggregate unclaimed property exceeds $3,500 or a single unclaimed property exceeds $250.

The dormancy period for intangible property is generally five years from the date of last activity, unless otherwise specified by the statute. For financial institutions, key differences include:

Money orders: 7 years

Traveler’s checks: 15 years

Pension, profit sharing, IRA, Keogh: 3 years

A complete list of property codes and descriptions along with dormancy periods and deduction codes, is Exhibit A to this guide.

Who Must Report Unclaimed Property?

Any holder of unclaimed property has a reporting and remittance obligation. This includes virtually all types of public and private entities. The requirement is not just limited to banks or credit unions; it includes all types of financial institutions such as insurance, investments and securities firms. It covers public entities like courts, government agencies, and political subdivisions (such as cities, counties, municipal districts, etc.). Non-profit organizations such as hospitals are also covered. The catch-all phrase “any legal or commercial entity” is used to pull every other type of business or organization within the purview of the rules. A report is NOT required if you do not hold any unclaimed property. However, for financial institutions, the filing of a null report is considered a best practice for ensuring consistency and accuracy of recordkeeping.

When Must We File Our Report?

All reports must be filed not later than November 1 of each year (May 1 for life insurance companies). The annual reporting period goes from July 1 of the previous year to June 30 of the year in which the report is filed. So, for example, the report that will be submitted on November 1, 2010 will cover property that became dormant any time between July 1, 2009 and June 30, 2010.

How May We File Our Report?

Both paper and electronic filings are accepted by the Colorado State Treasurer. A complete report consists of two forms:

Form A, a cover sheet that identifies your transmittal; and

Form B, which lists the property you are remitting.

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If you file electronically, the Colorado State Treasurer’s web site suggests using the web site www.wagers.net to obtain free reporting software.

What if We Don’t File?

1. You may have to pay interest on amounts you should have remitted. Interest accrues at the

annual rate of 18% of the property value from the date the property should have been paid or delivered. Interest stops accruing when the property is paid or delivered, and any outstanding interest balance is paid in full.

2. You may be fined for intentionally failing to report. This civil penalty is $100 a day for each day the report is withheld, up to $5,000 maximum.

3. You may be fined for intentionally failing to deliver property. This civil penalty equals 25% of the value of the property that should have been paid or delivered.

Errors that are not intentional (“willful”) and resulted from honest mistakes are unlikely to receive harsh penalties. However, your institution must have well-defined processes and procedures in place to support the conclusion that an error was inadvertent. It is considered a “best practice” to have written procedures for unclaimed property reporting. An institution with no protocols, or ones that are poorly-defined, is at greater risk of being found in non-compliance.

Before remitting property to the State, you must attempt to locate and notify the property owner. You should also inform the owner how to claim the property so that it is not turned over. The law gives property owners an opportunity to claim their property before it is turned over to the State. It accomplishes this objective by requiring holders to notify owners of the abandoned status of the property.

What Are the Notice Requirements?

The law states that not more than 120 days before filing the report, the holder shall send written notice to the apparent owner’s last-known address, informing the owner that the holder has property that may be remitted to the state. [See C.R.S. 38-13-110(5)] This notice must be delivered if both of the following conditions are met:

1. The holder’s records do not indicate that the last-known address is inaccurate; and 2. The property is valued at fifty dollars or more.

The law does not specify the minimum time frame before reporting that the notice must be given. However, you should deliver the notice within a reasonable amount of time before filing, to give the owner an opportunity to contact you to prevent the reporting and remittance. For example, a sixty-day

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advance notice might be considered reasonable, while one given five days prior to the reporting deadline likely would not.

What Must the Notice Say?

There is no particular language prescribed in the statute. Most notices:

Inform the owner that the holder is in possession of property that is subject to the Unclaimed Property Act;

Advise the owner that if s/he does not contact the holder prior to a specified date (usually a few weeks before the reporting deadline), that the property will be turned over to the State Treasurer; and

Provide contact information and instructions for how to contact the holder to prevent the reporting and remittance.

What if a Notice is Returned as Undeliverable?

This is a common occurrence. There is no particular action that the law requires you to take. However, it is considered a best practice to keep the returned mail along with your reporting and remittance records. This proves that you complied with the rule and attempted contact with the owner. Doing so also helps ensure that you can comply with the requirement to retain an owner’s last-known address for five years after the property becomes reportable.

How Far Must We Go in Trying to Find the Owner?

The law does not mandate that you take any particular action other than sending the required notice. You are not obligated to “hunt down” the property owner. But keep in mind that in order for bank deposits to meet the definition of “abandoned” under the statute, the owner must have had no communication or activity for the previous five years concerning either the abandoned account or any other relationship with the financial institution. [See 38-13-107(1)(e)] For this reason, you must compare your initial list of abandoned property to your other customer records. If a particular account has been dormant, but you have other active accounts held by the same owner, you should neither report nor remit the inactive account. Instead, you should communicate with the owner about the dormant account, using the address listed on the active account. An active account is one where the institution’s records demonstrate written communication from the owner, or memoranda or records showing that the owner has used or inquired about the account.

Example: Your abandoned property report shows checking account number 123456, owned by Roberta Williams, 123 Main Street, under Tax ID number 123-45-6789. You compare your records and find the same Roberta Williams with the same Tax ID number has two other active accounts. They both have recent activity, and both show a 456 Broad Street address. You should not remit account 123456. Instead, contact Roberta by phone or mail regarding the dormant account and obtain her instructions for what she would like to do with it.

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How far to go after making the comparison to active accounts is up to the institution. Some stop there. Others use other means, such as postal forwarding notices or skip tracing services, to try to locate the property owner. Remember that anything beyond what the law requires is optional and depends upon the institution’s own procedures.

Can We Assess Dormancy or Inactivity Fees or Stop Paying Interest on Unclaimed Property?

Yes, as long as three conditions are met:

1. A contract between the holder and property owner permits the fees or cessation of interest; 2. The holder notifies the owner of the fee or interest stoppage in writing to his or her last-known

address, at least three months in advance of the fee being imposed or interest ceasing; AND 3. The holder regularly imposes such fees or stops paying interest and does not regularly reverse

the charges or resume interest payments on the unclaimed property.

Special rules apply to securities, items held in safekeeping, and the contents of safe deposit boxes. These items are remitted differently than other types of property.

Securities must be delivered to the Treasury’s custodian, and the ownership legally transferred to the ownership of the state. In general, what you report must match what you deliver, and you must specifically describe the delivery by security name, CUSIP number, and number of shares. You must notify the State two days prior to delivery of the intended delivery. Reporting securities but delivering cash from the liquidation of the securities does not comply with the Unclaimed Property Act. Specific rules for securities can be found in Exhibit B.

Safekeeping Items (excluding safe deposit box contents) are reported on Form B, but are not given a value. You should physically deliver these items to the Treasury along with your report. Examples of items held in safekeeping may include intangible property you held as a service to a customer, such as deeds, wills, stock certificates or insurance policies. They may also include tangible property, such as jewelry, antiques, artwork, or other valuables.

Safe Deposit Box Contents are reported on Form B, but are not given a value. Remember that you report contents of boxes for which the rent expired five or more years ago and the owner has not claimed the contents. (Many institutions mistakenly report box contents upon the death of an owner. This is NOT the correct process!) If you have safe deposit box contents to turn over, you must contact the Unclaimed Property Division at the State Treasury for detailed instructions on how to inventory, package and deliver the property. Do NOT remit box contents until the Treasury instructs you to do so.

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A holder is allowed to deduct funds from the amounts remitted in two instances: (1) by an amount specified in the Unclaimed Property Act; or (2) if the holder has a legal or contractual right of offset in the property. The Unclaimed Property Act allows holders to deduct and retain from each remitted item an amount equal to 2% of the value of the property, or $25, whichever is less. For a few specified types of property, the permissible deduction is 2% of the value of the property or $25, whichever is greater. To identify which threshold applies, consult the Property Code/Description/Dormancy Period table attached as Exhibit A. This deduction is voluntary; a holder is not required to make or retain any deduction. [See 38-13-112 (1)(b)(II)]

Examples: Jan Jones received a cashier’s check for $200 when closing an account. The cashier’s check was never cashed. This category of item falls into the “whichever is less” category, so the deduction is the lesser of 2% ($4) or $25. You may deduct and retain $4 and remit $196. Mike Miller never cashed a $450 paycheck he was issued. This item falls into the “whichever is more” category, so the deduction is the greater of 2% ($9) or $25. You may deduct $25 and remit $425.

Can the Remittance be Offset by Amounts Owed to the Holder?

A holder is also entitled to exercise any legal or contractual rights of offset in the property before delivering it to the Treasury. [See 38-13-112 (1)(c )] For example, if you discover a deposit account balance owned by an individual who also had a charged-off loan, and your institution’s deposit contract specified that it could use the deposit funds to offset any amounts due the institution, the institution can apply the unclaimed deposit funds to the loan balance. Note that any excess balance remaining after applying the offset must still be reported and remitted.

Example: Bob Barnes abandoned a matured CD in the amount of $5000. When comparing Bob’s TIN to your records, you notice that he also previously defaulted on a credit card balance of $2000 which remains unpaid. You can deduct the amount owed from the credit card agreement from the remittance amount. Report only $3000 as the “amount due owner” in cell 10 on Form B.

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What If the Value of the Property is Less Than $25?

A holder is allowed to combine accounts or property valued at less than $25.00 and report the total of all property in that category under a single line item on the report. If the holder uses this reporting option, no deduction is allowed to be taken from the aggregate. What’s interesting about this option is that the recordkeeping rules still require a holder to submit and maintain a list of the owners of the aggregated funds and the amount of each item. The list must include the owner’s name, last-known address, and the amount of the property. Because of this, aggregate reporting may not provide a benefit to the reporter. For reporters who wish to take the allowable deduction, aggregating may not be the best option. The amount deducted from each item cannot exceed the amount due to the owner. So, for example, if the amount of property is $15.00, you can only retain $15.00, even if the property is of a type where you are allowed to deduct up to $25.00 under the “whichever is more.”

Completing the Forms If you submit a hard copy paper report, you must complete Form A and have an officer sign to attest to its accuracy. You must accompany this with a paper version of Form B. If you are filing electronically using NAUPA-approved software, you should follow the software provider’s instructions for the submission of the transmittal information and reporting form. Some software completes the entire process electronically, including the officer attestation. Other software requires that you mail the signed transmittal form even when transmitting the report electronically. Electronic filers should keep in mind that the instructions below correspond to item numbers on the paper forms. Electronic fields may differ. Refer to your vendor’s electronic filing guide for reporting instructions.

Form A: Transmittal Form

1. Enter your institution’s name, street address AND mailing address, city, state and zip code. 2. Enter your institution’s federal Employer Identification Number (EIN). 3. Enter the state in which and date that your institution was incorporated. Alternatively, enter

the state that is the institution’s principal place of business, and the date business began. 4. Fill in the appropriate circle to indicate the asset size of the institution. 5. Check the box to indicate your institution’s primary business activity. 6. Complete this section of your institution has ever reported under a different name. For

example, if your entity merged with another entity, and took the new entity’s name, you would enter your former name, former EIN and date of the change.

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7. Enter the contact information for two key roles at your institution: the person who should be contacted with questions about the report, and the person who should be contacted regarding claims to the listed property. Complete both sections even if the person in both roles is the same individual.

8. If you have reported items on the Colorado report to any other state, list the name(s) of the other state(s) to which items were reported.

9. An OFFICER of the institution must complete and sign this section. Print the officer’s name, the number of pages in the report, the totals remitted, and fill in the circle to indicate how the funds were remitted. The officer should sign and date the form, list his or her title and phone number.

10. If submitting by paper, mail the form to the address at the top of the form. If submitting electronically, follow the electronic provider’s instructions regarding whether a paper form must be submitted in addition to the electronic one.

Form B: Report of Unclaimed Property

1. Enter your institution name. 2. Number each page of the report with the page number and total number of pages. 3. Check the box to indicate your reporting period based on your entity type. 4. Enter the property code from the Property Code/Description/Dormancy table. 5. Enter the property description from the Property Code/Description/Dormancy table. Also enter

the identifying number (such as the account or instrument number) in this cell. 6. Enter interest being earned on the account, if any. 7. Enter the owner’s name and address information in the proper order. If the owner cannot be

identified, enter “UNKNOWN” in this field. 8. Enter owner’s SSN or EIN. 9. Enter the date of last activity, last maturity, or date the property became payable/redeemable. 10. Enter amount reported as due owner (enter the gross amount due before any deduction). 11. In (A), enter the code to indicate whether the allowable deduction is whichever is less than (L) or

more than (M) the 2% or $25 threshold. In (B), enter the dollar amount of the deduction being withheld from the remittance.

12. Enter the total amount remitted with the report (equals cell 10 minus cell 11B). 13. Enter the totals from each page of the report in cells 10, 11A, 11B and 12 for each page. 14. Enter the grand total for the entire report on the last page of the report. 15. Prepare check payable to the Colorado Department of the Treasury. 16. Mail check and form to the address on the top of the form.

Avoid these common errors to improve the accuracy and efficiency of your reporting process. Any erroneous information can cause your report to be rejected and/or your institution to be out of compliance with the Unclaimed Property Act.

Form A is not signed by an officer

Mathematical errors in calculations

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Check or balance remitted does not match report

Incorrect deduction codes

Incorrect deductions taken (wrong amount, or incorrectly taken on aggregate)

Not reporting amounts under $25 and retaining all such amounts

Incorrect or incomplete property codes

Insufficient or incomplete owner information

Failure to complete the interest field when applicable

Incorrectly placing “on file” in cell 8, owner SSN/EIN

Retain the proper records before, during and after filing the report. Good recordkeeping throughout the lifecycle of a business relationship helps holders to comply with these rules. Only with accurate records can a holder determine whether and when property may be considered abandoned. During the reporting cycle, a holder should keep records of the communications sent to owners of unclaimed property. This proves that the holder has complied with the notification requirements. Once a report has been filed, the law requires holders to keep copies of unclaimed property reports and supporting records for five years after the property becomes reportable. Such records should include as many of the following as are applicable:

The name of the owner(s), if identified;

The last known address of the owner(s);

The type and amount of property reported and remitted; and

The date of last activity or last contact with the owner(s).

Have a plan for how to respond when an owner contacts you, both before and after the report has been filed. Some property owners may contact your institution after receiving the notice of unclaimed property. This may happen both before and after your institution files the required annual report and remits the property. You need to have one or more individuals on your team who are the designated in-house experts on this process and can handle these inquiries in the proper manner.

What if the Owner Contacts Us Before We File?

If the owner contacts you BEFORE you report and remit, you can stop the reporting process and return the property to the owner. You will need a procedure to validate the identity of the person who is claiming to be the owner of the property, and establishing the validity of their claim. Once you have completed the validation process, you will need to keep records that prove that you paid out the property to the owner and that it was received by the owner (e.g., a cover letter transmitting a payment

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by check, along with proof that the check was eventually cashed). The retention of records of these communications helps fulfill your recordkeeping obligations. You are allowed to reactivate a dormant account upon the account holder’s request. In doing so, you must ensure that the owner can actually access the account. Retain proof of this accessibility along with the records you retain, to evidence compliance.

What if An Owner Wants to Claim Property After Funds Have Been Remitted?

You have the option to either accommodate this request or refuse it. Most institutions prefer to refuse the request and choose to refer owners to the State for making their claim.

If you refuse it, direct the property owner to the State for making a claim, as explained in the paragraph below.

If you decide to pay the claim, you can obtain a reimbursement from the State by completing a “Holder Reimbursement Form” found on the Treasury web site. You must also attach proof of payment for each owner paid, such as a copy of the cancelled check used to make payment.

If the owner contacts you AFTER you report and remit, you should explain that the funds already have been turned over to the State Treasury and provide instructions for contacting the Unclaimed Property Division. Doing a simple internet search for “Great Colorado Payback” will find the state’s web site. At this site, owners can find instructions for how to claim their property.

What if We Remitted too Much?

You may request a refund from the State if you have made an accounting error, or have remitted property that was not actually abandoned. To do so, write a letter to the Holder Compliance Section of the Unclaimed Property Division explaining the error and asking for a refund. Include any supporting documentation necessary to prove your explanation of the circumstances.

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Tips for an Effective Program Following these principles will ensure your process runs smoothly year after year:

Reduce your escheat process to writing. A written policy and procedures can help guide staff in performing their duties accurately and thoroughly.

Set up your process to run smoothly. With the reporting period ending on June 30, the first week of July should be devoted to matching records of dormancy against currently active accounts. By the second week of July, send notices to owners of unclaimed property.

Be sure that notices include all pertinent information for contacting the right individual within your organization who can assist owners in identifying and preventing remittance of their property.

Institute a secondary review of the report prior to filing. Ideally, someone other than the signing officer will prepare the report, which allows the signing officer to double-check it for accuracy and completeness. If this is not practical due to staffing constraints, another officer should at minimum double-check the report’s contents and arithmetic and compare those totals to the amount being remitted.

Maintain accurate and complete records of all contacts with account owners.

At least every other year, audit the process to ensure that procedures are being followed and that the institution is in compliance. The audit process should include:

o Reviewing records used to identify unclaimed property; o Determining that all classes of unclaimed property held by the institution have been

identified; o Verifying the timing and content of notices to owners meet compliance requirements; o Reviewing records of communication with owners who claimed property; o Sampling or “spot-checking” the filed report for accuracy of entries; o Verifying the adequacy of supporting documentation retained; and o Reviewing any communication between the institution and the State regarding the

institution’s compliance with the Act.

Ensure your institution’s contact information at the State is always kept current so that you will receive the latest updates to information and reporting requirements. Also monitor the “Great Colorado Payback” web site periodically to confirm your knowledge is current.

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Exhibit A: Code Sheet 2010

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Last Published: 08/10

Property Code/Description, Deduction Code and Dormancy Periods Property codes are adopted by the National Association of Unclaimed Property Administrators (NAUPA) and are in used in most states to report unclaimed property. Voluntary deduction from each remitted item: The law permits a holder to deduct and retain from each remitted item, 2% of its value or $25, whichever is less. This is represented by an “L” in the deduction code field. For some types of property, the rule allows retaining 2% or $25, whichever is more. This is denoted by an “M” in the deduction code field. Note that such deductions are not mandatory and are made at the holder’s sole discretion. Also note that the deduction must be calculated on a per-remitted-item basis, not upon the total of funds remitted. CODE DESCRIPTION DEDUCTION

CODE DORMANCY PERIOD (years)

ACCOUNT BALANCES

AC01 Checking/DDA L 5

AC02 Savings L 5

AC03 Certificates of Deposit (Matured) L 5

AC04 Christmas Club L 5

AC05 Money on Deposit to Secure Loans L 5

AC06 Security Deposits Dormancy period reduced to one year if the funds have been ordered refunded by a court or administrative agency and the owner has not claimed the funds within one year from the time of such order. See 38-13-107.3

L 5 or 1

AC07 Unidentified Deposits Dormancy period reduced to one year if the funds have been ordered refunded by a court or administrative agency and the owner has not claimed the funds within one year from the time of such order. See 38-13-107.3

L 5 or 1

AC08 Suspense Accounts L 5

UNCASHED CHECKS * Note: If an uncashed check represents account balances, deposit funds or insurance proceeds, the deduction is the lesser (L) of 2% or $25.

CK01 Cashier’s Checks and Garnishments * 5

CK02 Certified Checks * 5

CK03 Registered Checks * 5

CK04 Treasurer’s Checks * 5

CK05 Drafts * 5

CK06 Warrants * 5

CK07 Money Orders M 7

CK08 Traveler’s Checks M 15

CK09 Foreign Exchange Checks M 5

CK10 Expense Checks M 5

CK11 Pension Checks M 5

CK12 Credit Checks or Memos M 5

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Exhibit A: Code Sheet 2010

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Last Published: 08/10

CODE DESCRIPTION DEDUCTION CODE

DORMANCY PERIOD (years)

CK13 Vendor Checks M 5

CK14 Checks Written off to Income * 5

CK15 Outstanding Official Checks * 5

CK16 Interest Checks for Certificates of Deposit L 5

SAFE DEPOSIT BOXES AND SAFEKEEPING

SD01 Safe Deposit Box Contents N/A 5

SD02 Safekeeping Items N/A 5

SD03 Other Tangible Property Held in Safe Deposit or Safekeeping N/A 5

SD04 Unclaimed Loan Collateral Held in Safe Deposit or Safekeeping N/A 5

TRUST/ INVESTMENT/ ESCROW ACCOUNTS

TR01 Paying Agent Accounts M 3

TR02 Dividends – Undelivered or Uncashed M 3

TR03 Funds Held in a Fiduciary Capacity M 3

TR04 Escrow Accounts M 3

TR05 Trust Vouchers M 3

TR06 Pre-Need Funeral Payments M 3

SECURITIES

SC01 Dividends M 5

SC02 Interest on Registered Bonds M 5

SC03 (This number is missing from the state list.)

SC04 Equity Payments M 5

SC05 Profits M 5

SC06 Funds for Purchase of Shares or Interest M 5

SC07 Bearer Bond Interest on Matured Principal M 5

SC08 Shares of Stock N/A 5

SC09 Cash for Fractional Shares M 5

SC10 Unexchanged Stock of Successor Company N/A 5

SC11 Any Other Certificate of Ownership N/A 5

SC12 Underlying Shares of Outstanding Certs N/A 5

SC13 Liquid Funds from Redemption of Stock M 5

SC14 Debentures, Bonds, Coupons N/A 5

SC15 U.S. Government Securities N/A 5

SC16 Mutual Funds N/A 5

SC17 Warrants/Rights N/A 5

SC18 Registered Bonds - Matured Principal M 5

SC19 Dividend Reinvestment Plan M 5

SC20 Credit Balances M 5

INSURANCE

IN01 Individual Policy Benefit or Claims Payments L 5

IN02 Group Policy Benefit or Claims Payments L 5

IN03 Death Benefits due Beneficiary L 5

IN04 Matured Policy, Endowment or Annuity Note: Dormancy period is 5 years, but this is reduced to 2 years if the insured has or would

L 5 or 2++

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Exhibit A: Code Sheet 2010

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Last Published: 08/10

CODE DESCRIPTION DEDUCTION CODE

DORMANCY PERIOD (years)

have attained the limiting age under the mortality table on which the reserve is based. See 38-13-109.5

IN05 Premium Refund on Individual Policy L 5

IN06 Unidentified Remittances L 5

IN07 Other Amounts Due Under Policy L 5

IN08 Agent Credit Balances M 5

MISCELLANEOUS CHECKS AND INTANGIBLE PERSONAL PROPERTY held in the ordinary course of business

MS01 Payroll, Wages or Salary M 1

MS02 Commissions M 5

MS03 Worker’s Compensation Benefits M 1

MS04 Payment for Goods and Services M 5

MS05 Customer Overpayments M 5

MS06 Unidentified Remittances M 5

MS07 Unrefunded Overcharges M 5

MS08 Accounts Payable M 5

MS09 Credit Balances and Accounts Receivable M 5

MS10 Discounts Due M 5

MS11 Refunds Due M 5

MS12 Unredeemed Gift Certificates M 5

MS13 Unclaimed Loan Collateral M 5

MS14 Pension, Profit Sharing, IRA or Keogh Funds M 3

MS15 Proceeds from Dissolution or Liquidation of Property M 1

MS16 Miscellaneous Outstanding Checks M 5

MS17 Other Miscellaneous Intangible Personal Property M 5

MS18 Suspense/Liabilities M 5

Other categories available for use include Utilities, Courts and Public Agencies, and Proceeds from Mineral Investments. Refer to http://www.colorado.gov/treasury/gcp/generalreportinginfo.html for more information if you are a holder of these types of funds.

Page 17: Colorado Unclaimed Property Reporting Guide 2010

Exhibit B: Securities 2010

Page 17 of 18 Last revised: 09/00

Last Published: 08/10

Special Rules for Delivering Securities to the Colorado State Treasurer

Securities must be transferred into the ownership of the State. Your report is not complete until you provide evidence of the transfer. Two days before delivering the securities, a holder must email a list of intent to deliver to [email protected]. Include the CUSIP number, security name, share amount, broker’s DTC number, and, if applicable, the account number at the fund for Mutual Fund Securities.

Type of Security Registration Information

DTC Eligible Shares Must be deposited through DTC or DWAC

Nominee: Colorado & Co FEIN 33-1059621 DTC Participant #0954 Agent Bank # 26017 Account # AUZF0176702

Book Entry/DRP/Direct Registration Shares A copy of a confirmation showing Colorado & Co as the owners of the shares must accompany your report.

PRIMARY ADDRESS FOR MAILING STATEMENTS AND CHECKS Nominee: Colorado & Co FEIN 33-1059621 c/o ACS Unclaimed Property Clearinghouse 260 Franklin Street, 11th Floor Boston, MA 02110 SECONDARY ADDRESS FOR STATEMENTS AND CHECKS State of Colorado Unclaimed Property Division 1580 Logan Street, Suite 850 Denver, CO 80203 Instruction: Reinvest dividends

Physical Certificates (for non-DTC eligible shares only) Send the original certificate to the custodian whose address is listed in the right column. Submit a photocopy of the certificate with your report. One certificate per security position

ADDRESS FOR CUSTODIAN Nominee: Colorado & Co FEIN 33-1059621 Attn. Mike Visone Mellon Security Trust Company One Wall Street, Third Floor Receive Window C New York, NY 10271 48 hours before delivery, fax certificate copies or a list of securities (name, CUSIP #, share amount, certificate number) to 617-711-9660, Attn. Loreta Pingo

Page 18: Colorado Unclaimed Property Reporting Guide 2010

Exhibit B: Securities 2010

Page 18 of 18 Last revised: 09/00

Last Published: 08/10

Type of Security Registration Information

Open End Mutual Funds Register in name of MAC & CO ACS will provide account numbers. Contact Mike Giurleo at 617-722-9614 48 hours prior to delivery to obtain account numbers.

ADDRESSES FOR INTERESTED PARTY STATEMENTS ACS Unclaimed Property Clearinghouse ATTN: Mutual Fund Operations 260 Franklin Street, 11th Floor Boston, MA 02110 AND MAC & CO – Account AUZF0176702 State of Colorado Mutual Fund Operation P.O. Box 3198 Pittsburgh, PA 15230-3198 Account # AUZF0176702 FEIN 25-1536944 Distribution Options: Reinvest income, dividends, capital gains

Closed End Mutual Funds

Colorado & Co TIN 33-1059621 c/o ACS Unclaimed Property Clearinghouse 260 Franklin Street, 11th Floor Boston, MA 02110 Distribution Options: Reinvest income, dividends, capital gains

Foreign Securities

Get delivery instructions from Loreta Pengo, 617-371-9934

Federal Reserve Book Eligible Securities

Reserve Bank of New York ABA #0210-0001-8 BK of NYC/TRUST FBO State of Colorado, Account # AUZF0176702

Securities-Related Cash

Report and remit on Form B