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ARTICLE · 12 OCTOBER 2017

Get Ready For The Countdown: Final Delaware Unclaimed Property Regulations Published

McDermott Will & Emery
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On October 1, 2017, the Delaware Department of Finance published final regulations in the Register of Regulations repealing its former unclaimed property regulations and promulgating...

United StatesAccounting and Audit
Stephen Kranz
Stephen Kranz
Diann Smith
Diann Smith
Eric Carstens
Eric Carstens
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On October 1, 2017, the Delaware Department of Finance published final regulations in the Register of Regulations repealing its former unclaimed property regulations and promulgating a new reporting and examination manual. See 21 DE Reg 336 (Oct. 1, 2017). The final reporting and examination regulation contains no substantive changes from the revised version that was re-proposed on August 1, 2017. As published, the regulations are set to be adopted and take effect on October 11, 2017.

This development is significant for holders that are currently under audit and considering enrolling in the Secretary of State's Voluntary Disclosure Agreement Program (VDA Program) or converting the audit to an "expedited audit" because October 11 marks the start of the 60-day period allotted for holders to notify the Secretary of State and/or State Escheator of their intention. See 12 Del. Code § 1172(b)-(c). At the conclusion of this 60-day period, any holder that has not provided a

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