should be considered. Unclaimed Property policies and procedures applicable to the disbursement process should be evaluated to ensure transactions associated with the midstream sector are included. To help ensure a complete review, the void procedure should be evaluated to verify that it does not circumvent controls that would allow for recognition of transactions that may need to be further investigated, as well as undistributed balances resulting from questions of ownership. Midstream exposures should be recognized as potential unclaimed property and allowed to age in order to determine if it should be reported to the applicable State in the unclaimed property reporting process. Policies and procedures should also be developed to help ensure ongoing compliance into the future. Finally, companies that operate in various streams should coordinate efforts between the Land or Division Order units to help ensure consistent applications of state requirements throughout the organization.
About the Authors:
Ann Fulmer, CPA, CIA, CFE National Practice Leader Keane Consulting
Gary Joseph, MBA, CIA Senior Manager Keane Consulting
NADOA Welcomes the following NEW MEMBERS!!
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