The clock is running

For most banks, the annual unclaimed property report is due November 1. That leaves only a few weeks to find every dormant account, finish owner outreach, build the report and send the money to the state.

This year has a small wrinkle. November 1, 2026 falls on a Sunday. Wisconsin, for example, moves its due date to the next business day when that happens. Don’t count on the extra day, though. Some states set their deadline at October 31, and the rules differ by state.

This checklist walks compliance and operations teams through what to confirm now. It also covers the mistakes that most often lead to penalties and audits.

This article is for general information only and is not legal advice. Always confirm requirements with each state or your legal counsel.

What counts as unclaimed property for a bank

Unclaimed property is money or assets a customer has stopped interacting with. After a set period of inactivity, the bank must report it and turn it over to the state. That process is called escheatment.

For banks, the most common types are:

• Dormant checking and savings accounts
• Uncashed cashier’s checks and official checks
• Matured CDs with no customer contact
• Safe deposit box contents
• Customer credit balances and refunds

The waiting period before property is considered abandoned is called the dormancy period. The OCC generally puts it at three to five years for bank accounts, depending on state law. Other property moves faster. Texas, for example, uses a one-year period for wages and utility deposits but five years for safe deposit box contents.

The key date is the last customer-initiated activity. A deposit, withdrawal, login or written contact usually resets the clock. Bank-initiated activity, like posting interest or charging a fee, usually does not.

Not every state is November 1

Most states use a July 1 to June 30 reporting period with a fall deadline. But a bank with customers in several states may owe reports on different dates, and property is generally reported to the state of the owner’s last known address.

Life insurance companies often follow a separate spring schedule. In Ohio, for example, life insurers report by May 1 instead of November 1.

Negative reports vary too. Ohio requires a report even when there is nothing to report. North Carolina does not. Indiana does not require one by statute, but expects them.

Your last-minute checklist

Use these seven steps to pressure-test your report before it goes out.

1. Confirm every state you owe. List each state where you have account owners with reportable property. Then match each one to its deadline and report period.
2. Run a fresh dormancy pull. Pull accounts that crossed their dormancy threshold as of June 30. Include all account types, branches and core systems, not just checking and savings.
3. Check that owner outreach happened on time. Most states require a letter before reporting. Indiana requires notice for property of $50 or more, sent 60 to 180 days before the report is filed. If a customer responds, remove that account from the report.
4. Scrub for reactivated accounts. Accounts that saw real customer activity after the pull should come off the list. Reporting an active customer’s money is a service failure, not just a compliance one.
5. Build the report in NAUPA format. Most states now expect electronic files in the National Association of Unclaimed Property Administrators standard. Indiana, for example, requires electronic NAUPA-format reports.
6. Decide now if you need an extension. Extension rules differ. Ohio offers one extension per year of 30 to 120 days. Indiana requires a written request at least 30 days before the deadline, which means early October.
7. Save the paper trail. Keep copies of reports, due diligence letters and remittance records. Indiana guidance tells holders to keep supporting documents for 10 years.

Common mistakes and what they cost

Late or incomplete reports are expensive, and the penalties add up fast. A few examples:

• California can charge 12% annual interest plus $100 per day for unfiled reports, up to $10,000.
• Michigan can impose up to 12% interest and $100 per day, capped at $5,000.
• Texas adds a 5% penalty for reports 1 to 30 days late and 10% after that.

The bigger risk is an audit. State audits and their contract auditors often look back 10 to 15 years. Missing a deadline after filing in prior years can raise a red flag with the state.

Many compliance gaps come from simple process problems:

• Tracking dormancy in spreadsheets that live with one person
• Missing property types outside deposit accounts, like official checks and safe deposit boxes
• Mailing due diligence letters too early or too late
• Treating bank-initiated activity as customer contact
• Losing the documentation needed to defend a report later

If you find past gaps, most states offer voluntary disclosure programs. These often waive penalties and interest if you come forward before the state contacts you.

After November 1: make it a year-round process

The banks that handle this season calmly treat unclaimed property as an ongoing workflow, not a fall scramble. That means watching dormancy continuously, tracking deadlines by state and keeping records audit-ready all year.

That is exactly what Gemini’s Unclaimed Property Services are built to do. We help community banks, regional institutions and multi-state organizations:

• Monitor dormant and inactive accounts automatically, with custom thresholds by state
• Track state reporting deadlines with alerts and notifications
• Validate records and manage the documentation behind each report
• Keep historical reports and activity organized for examinations and audits

Our document management team can also convert paper records into searchable digital files, so the proof you need in an audit is easy to find.

Get ahead of next year’s deadline. Schedule a free discovery call and we’ll look at how your team handles unclaimed property today.

Sources

• Wisconsin DOR, Unclaimed Property Holder Report Guide (Pub. 82)
• North Carolina Department of State Treasurer, Holder FAQ
• Ohio Department of Commerce, Unclaimed Funds reporting reminder
• Texas Comptroller, Dormancy periods
• Indiana State Board of Accounts, Unclaimed Property presentation
• Sovos, Indiana Escheat & Unclaimed Property Laws
• Eisen, Abandoned Property Laws by State (2026)
• Eisen, Indiana state guide
• Eisen, New York state guide
• Eastman & Smith, Ohio unclaimed funds reporting
• Dunbar Group, California banks and unclaimed property
• UPCR, Michigan unclaimed property guide
• UPCR, Texas unclaimed property guide
• Crowe, 10 Answers to Common Unclaimed Property Questions
• PYMNTS, Penalties Loom on Unclaimed Property Reporting
• InCharge, Dormant Bank Account Rules