The New Regulatory Focus on Unclaimed Property

Additional Challenges for the Investment Industry


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 Guidehouse’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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