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NAUPA 3 Reporting Updates—How to Prepare Your Process

The New Standard Electronic File Format Is Coming

It has been nearly two decades since the last update of the National Association of Unclaimed Property Administrators (NAUPA) electronic reporting standard. As the NAUPA reporting standard reaches across national borders, more than a few companies will struggle to adapt their escheatment process to this innovation. Our blog covers three steps the office of finance should take to remain compliant as reporting standards evolve with NAUPA 3. It is generally less expensive—in fines and reputation loss—to establish reporting principles proactively than to pay the price for non-compliance.

1. Leave Spreadsheets Behind

When NAUPA’s first reporting standard was established in the mid-1990s, floppy disks were still the height of data storage. After the NAUPA 3 update is finalized this year, it’s standards will reflect current technologies and information that had not been previously tracked.

As the NAUPA reporting standard has lagged in response to technological innovation, so has the management of reporting and remittance activities. Many organizations continue to rely on disconnected spreadsheets and emails to complete their escheatment. Unfortunately, this process is not only slow but wastes valuable resources while increasing the risk of non-compliance. Furthermore, included in the NAUPA 3 revamp are expanded holder and property data elements. Standardizing the collection, retention, and reporting of that data through an automated solution would increase the process’ efficiency and effectiveness by eliminating the risk of data entry error.

2. Maintain Strong Controls

Not only has technology usage progressed since NAUPA II was implemented, but legal compliance standards concerning confidential client data have also evolved, namely with the landmark healthcare law HIPAA. Though HIPAA was first mandated in 1996 laws are also open to updates, and the HIPAA Security Rule did not go into effect until after the last NAUPA update was finalized1. Now, when Protected Health Information (PHI) is involved, reporting organizations will need to factor HIPAA compliance into their escheatment process.

Implementing an automated escheatment solution enables organizations to easily prove their compliance with PHI and PII through the visibility and standardization of clear audit trails. NAUPA 3 will have built-in indicators to alert reporting organizations to the presence of protected client data, and your remittance process should be similarly standardized.

3. Step into the Digital Age

Not only has technology become more digital in the 16 years since the last NAUPA update, so have the types of property to be remitted. Recently, blockchain products such as Bitcoin and other cryptocurrencies have become increasingly popular2. Managing such complex property data with manual methods is inefficient and leaves the process open to security breaches. As mentioned earlier, reporting data elements have not only become more complex but more numerous—can your manual methods keep up?

As an automated solution to evolving reporting requirements, Unclaimed Property Compliance System (UPCS®) by Trintech is being proactively updated in accordance with NAUPA 3. The escheatment process is changing to meet modern technology usage, so the office of finance’s technology should be on the same level. By taking these steps, you can achieve increased visibility and efficiency throughout your process to ensure you meet your compliance obligations.

To learn more about automating your unclaimed property reporting to be NAUPA 3 compliant, check out our solution.

Written by: Chelsea Downey

[1] HHS. (n.d.). The security rule. Retrieved February 8, 2019, HHS.gov.
[2] Beyer, E. (September 12, 2018). Bitcoin tax laws virtually nonexistent in states. Retrieved February 8, 2019, BNA.