Tuesday, September 21, 2010

NJ Publishes Gift Card Reporting Guidelines

Pursuant to new legislation enacted earlier this summer (see prior coverage here and here), holders will have to begin reporting stored value cards, such as gift cards, to the State of New Jersey as unclaimed property.  In order to facilitate holders' first-time reporting of this property, the New Jersey Department of Treasury has recently published guidelines for the reporting of stored value cards.

Under New Jersey law, unclaimed property reports are due on or before November 1.  The guidelines issued by the Treasury Department suggest (but do not require) that holders file two separate reports:  one for stored-value cards, and one for all other property.  Among other provisions, the guidelines also provide that:
  • Holders should not report gift cards in the aggregate (regardless of dollar amount).
  • "Pay cards" - stored value cards issued in place of wages - have a 1 year dormancy period.
  • there is a 5 year reach back period for stored value cards - all items with issue dates of July 1, 2003 are subject to the Act.  There is no reach-back period for pay cards - all items are subject to the Act.
  • Property type MS12 should be used for most stored value cards, property type MS01 for pay cards.
  • Ifthere is no owner address information, the holder should list the zip code of where the card was sold.

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