Minnesota has announced a new voluntary compliance initiative in conjunction with the recent approval for the Minnesota Department of Commerce (“Department”) to hire additional full-time employees to assist with unclaimed property enforcement and compliance endeavors. This new Voluntary Disclosure Agreement (VDA) program will serve as a key component and incentive in Minnesota’s efforts to help holders come into compliance.
Under certain circumstances, the VDA program provides holders the opportunity to report past-due property without interest and penalties. The look-back period under the VDA includes 10 reporting years, plus 3 years of dormancy. Holders that are already under audit or have received a notification of audit are not eligible to participate.
Minnesota has already disseminated outreach letters to hundreds of businesses across all industries informing them of the Department’s new compliance efforts including the possible use of a VDA agreement. Failure to respond could lead to audit. Holders accepted and enrolled in the program will be required to complete a comprehensive review of their prior and current reporting procedures and to identify any potential funds that are due to the state of Minnesota as required by Minnesota statute. The state encourages all holders to take advantage of this voluntary compliance initiative.
A select group of holders has also been identified and will be receiving an audit notification. These holders will likely be subject to a look-back period of at least 20 years, plus dormancy. It is highly encouraged that holders enroll in the new Voluntary Compliance Initiative to avoid audit situations such as this.
Please contact Valerie Jundt, Managing Director (firstname.lastname@example.org) of Consulting and Advisory Services at Keane for additional information on this or any other state’s compliance initiatives. We will continue to monitor the Minnesota VDA program and its results on our Unclaimed Property Blog and in our Unclaimed Property newsletter, Keanotes.