The New Regulatory Focus on Unclaimed Property

Additional Challenges for the Investment Industry

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The unclaimed property compliance landscape is becoming more complex and increasingly burdensome for financial institutions. Most of this is due to the regulatory changes, including SEC Rule 17Ad-17, updated dormancy periods, expansion of abandonment triggers, third-party audits and advancements in technology and data analytics.

What does this mean?

  • Increased scope in the identification of Unclaimed Property triggers that can lead to greater liability for non-escheated assets.
  • Companies need the ability to systematically track and report on all Unclaimed Property triggers.
  • An increased need to be able to view customers across multiple businesses, as auditors are tracking OGA across companies’ entire enterprise.
  • A renewed interest to ensure proper Unclaimed Property documentation and processes are in place across the enterprise and those processes are compliant.
  • Consider implementing technology solutions to manage and track regulations, triggers, and compliance.
  • Increased risk of exposure through lawsuits due to pre-mature escheatment.

In Navigant’s recent article The New Regulatory Focus on Unclaimed Property: Additional Challenges for the Investment Industry, our experts discuss the changing unclaimed property landscape and the new rules or changed regulations impacting it.

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