2021 Q4

the statutory requirements in Ohio Revised Code Section 169.03(E), to the last-known address of the owner or beneficiary of dormant accounts; 2. For dormant accounts with a balance of at least $50 and less than $1,000 the OUF-8 Notice of Unclaimed Funds must be sent via first-class mail. 3. For dormant accounts with a value of $1,000 or more the OUF-8 Notice of Unclaimed Funds must be sent by certified mail, return receipt requested. 4. The company is authorized to charge each account subject to the mailing up to $20 to reimburse themselves for the certified mail cost. Include a self- addressed, stamped, return envelope.

5. The company must allow a minimum of 30 days for the owner or beneficiary to respond to the OUF-8 Notice prior to reporting the funds to the Division as unclaimed funds. 6. Accounts with a balance of $50 or more with mail returned for bad address, and those whose owner or beneficiary does not respond, are reportable to the Division as unclaimed funds. 7. An OUF-8 Notice of Unclaimed Funds mailing is not required to be sent to owners of dormant accounts valued at less than $50.00. However, please note, accounts with valued at less than $50.00 are still reportable unclaimed funds as an aggregate total.

Managing Unclaimed Property in Energy Sector By Jinu Thomas, Paola Narez and Gary Joseph

Sovos’ Consulting and Compliance teams closely monitor legislation changes and work to provide timely updates to clients and the industries in which they operate. The unclaimed property landscape has undergone significant changes over the past couple years. From states such as Colorado adopting current to pay provisions (“CTP”), to Texas requiring consolidation of unclaimed property reports, holders must stay vigilant to maintain compliance. Speaking of dynamic and drastic changes to unclaimed property state laws, Delaware has been notably busy this year. Delaware enacted Senate Bills 103 and 104 this past summer, which impacted a wide range of topics that include, but are not limited to:

● Third party auditor payment structure transition from contingent fee to hourly basis ● Prohibition of joint audits with Delaware ● Extending the response period for a Holder to accept the Delaware Voluntary Disclosure Agreement (“DE VDA”) invitation by entering the program from 60 to 90 days after delivery of the invitation ● While some are favorable, there are changes that raise concern and require subject-matter expertise to properly manage. One of these changes is the request for verification or compliance review notices. The following success stories demonstrate how Sovos has fielded and assisted clients in the energy sector to respond to these notices. Example #1: DE Verification Notice A mid-sized, vertically integrated energy company received a Verified Report notice from the Delaware Department of Finance, demanding a copy of the company’s complete entity list associated with its 2019 filing, as well as its unclaimed property

● Due diligence during examinations ● The state’s authority to determine the completeness and accuracy of reports by way of verification and compliance engagements

G r o w t h T h r o u g h E d u c a t i o n - O c t o b e r / N o v e m b e r / D e c e m b e r 2 0 2 1 19

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