Wednesday, March 9, 2016

Delaware Proposes New VDA and Audit Guidelines - Comments Welcome

The Delaware Department of Finance has posted proposed regulations for public comment to govern the state's unclaimed property audits and VDA proposals.  The proposed regulations are intended to implement the Delaware legislature's direction "to complete the development of a detailed manual containing procedural guidelines for the conduct of Delaware unclaimed property examinations" as per January 2015's Senate Bill 11.

Among the highlights of the proposed regulations relating to VDAs administered by the Department of Finance* is the establishment of a "rolling look-back date of 19 report years" for all VDAs entered into on or after January 1, 2017.

The proposed audit regulations include details regarding the appropriate sampling and estimation methodologies, rules for the auditor's conduct of the audit, procedural steps, as well as a sample (though very summary) non-disclosure agreement acceptable to the state.

The proposed regulations also contain a list of information and factors that may be used to select a holder for audit.  These include a review of the holder's reports for "inconsistencies, omissions or a lack of detail" and a "comparison of a Holder’s past reports to the reports of similar Holders within the same industry and of the same approximate size." 

Comments are due to the Department of Finance by 4:30 p.m. on April 1.

*  By virtue of legislation enacted in 2012, the Delaware Secretary of State's office also administers a Voluntary Disclosure Agreement program for holders of unclaimed property.  The proposed regulations above relate to the Department of Finance program.  Implementing guidelines for the Secretary of State's program can be found here.

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