The Delaware secretary of state promulgates important unclaimed property VDA guidance *

USA - November 29 2012
On July 11, 2012, Delaware Governor Jack Markell signed Senate Bill 258 (S. 258) into law, thereby granting the Secretary of State (as opposed to the State Escheator) a limited three-year window to enter into voluntary disclosure agreements (VDAs) with holders of unclaimed property (the “New VDA Program”).

Co-authors: Michael M. Giovannini, Ethan D. Millar, John L. Coalson, Jr., Kendall L. Houghton, Matthew P. Hedstrom.

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Unclaimed property update: Delaware promulgates audit look-back regulation and the Supreme Court denies cert. in New Jersey stored value card litigation *

USA - November 9 2012
This advisory addresses two recent developments of particular importance to holders of unclaimed property: (1) Delaware’s promulgation of a regulation impacting the look-back period for unclaimed property audits and (2) the U.S. Supreme Court’s denial of certiorari in the ongoing New Jersey stored value card litigation.

Co-authors: Michael M. Giovannini, Ethan D. Millar, John L. Coalson, Jr., Kendall L. Houghton, Matthew P. Hedstrom.

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New Verus unclaimed property audit initiative branches out *

USA - October 9 2012
We have learned that Verus Financial, LLC (“Verus”), the contract audit firm recently known for conducting multistate unclaimed property examinations of the insurance industry, has begun to focus its audit activity on companies in the securities/financial products and services arena.

Co-authors: Michael M. Giovannini, Ethan D. Millar, John L. Coalson, Jr., Kendall L. Houghton, Matthew P. Hedstrom.

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Federal consumer protection agency to determine whether federal law preempts application of state unclaimed property laws to unredeemed gift card balances *

USA - August 20 2012
The Consumer Financial Protection Bureau (CFPB) is a federal agency created in 2010 and is tasked with protecting consumers by carrying out federal consumer financial laws.

Co-authors: Michael M. Giovannini, Ethan D. Millar, John L. Coalson, Jr., Kendall L. Houghton, Matthew P. Hedstrom.

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New Jersey stored value card update *

USA - July 2 2012
Last Friday, June 29, 2012, Governor Christie signed into law Senate Bill No. 1928 (S.1928) (which is identical to Assembly Bill No. 3045), which substantially modifies the controversial New Jersey stored value card unclaimed property legislation adopted in 2010 (P.L. 2010, c. 25).

Co-authors: Michael M. Giovannini, Ethan D. Millar, John L. Coalson, Jr., Kendall L. Houghton, Matthew P. Hedstrom.

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