Why formal policies and procedures matter

Beyond supporting operational consistency, comprehensive policies and procedures provide protection during state examinations, demonstrate compliance commitment to regulators, and preserve knowledge when team members change.

Well-designed unclaimed property policies and procedures deliver multiple strategic benefits:

Audit protection

Documented procedures demonstrate good faith compliance efforts, potentially reducing penalties and assessments.

Knowledge preservation

Comprehensive documentation ensures continuity through staff transitions.

Compliance consistency

Standardized processes help prevent gaps in property identification and reporting.

Cross-functional alignment

Clear documentation helps align finance, legal, tax, and operations teams.

Training foundation

Documented procedures provide the basis for effective staff training.

The key components of unclaimed property policies and procedures

Effective unclaimed property policies and procedures typically include the following elements, each designed to support compliance, consistency, and risk mitigation across the organization.

Property type identification

• Comprehensive inventory of property types relevant to your organization

• Department-specific guidelines for identifying potentially escheatable property

• Criteria for determining when property becomes dormant

• Documentation requirements for property status changes

Established due diligence process

• Timing and frequency of owner outreach attempts

• Communication templates and delivery methods

• Response tracking and documentation protocols

• Escalation procedures for unresponsive owners

Record retention standards

• Retention periods for key documentation types

• Storage formats and systems

• Retrieval procedures for historical records

• Documentation standards for property dispositions

Reporting workflows

• State-specific filing requirements and deadlines

• Internal preparation and review procedures

• Management approval processes

• Filing documentation and confirmation procedures

Remediation protocols

• Procedures for addressing identified compliance gaps

• Voluntary disclosure assessment guidelines

• Internal reporting of potential issues

• Correction of past filing errors

Common documentation gaps

Across industries we have identified several common gaps in unclaimed property documentation.

Limited property type coverage

Many organizations document procedures for only a subset of potentially escheatable property types.

Inconsistent interdepartmental processes

Different departments often follow inconsistent approaches to similar property types.

Incomplete responsibility assignments

Unclear ownership of specific unclaimed property tasks creates compliance vulnerabilities.

Insufficient review procedures

Many organizations lack formal quality control and review processes.

Inadequate state-specific customization

Policies often fail to address variations in state-specific requirements.

How Sovos can help

Sovos Unclaimed Property Consulting provides comprehensive policy and procedure development services tailored to your organization's specific needs.

Our P&P development approach

With industry-specific expertise developed through more than 200 hours of unclaimed property experience, our team can help your organization develop and implement policies and procedures that strengthen compliance while reducing administrative burden. Services we offer:

• High-level review of current operating procedures impacting unclaimed property compliance

• Industry-specific best practices to help reduce exposures and retain client assets

• Customized documentation that meets state and money transmitter audit requirements

• Implementation guidance to ensure effective adoption across your organization

• Ongoing support to address questions

Beyond documentation - creating a compliance culture

While comprehensive documentation is essential, effective unclaimed property compliance also requires the following elements. Sovos can support your organization in developing these alongside your formal policy and procedure documentation.

• Leadership engagement demonstrating commitment to compliance

• Regular training for key personnel across departments

• Periodic review and updates to address changing requirements and business practices

• Compliance incentives that reinforce the importance of proper procedures

• Technology enablement to streamline identification and reporting processes

Interested in Sovos Unclaimed Property Consulting services?

Contact us to discuss your organization's unclaimed property needs.