Voluntary Disclosure Program Frequently Asked Questions
The Voluntary Disclosure Program (VDP) is a program designed by the Unclaimed Property Division to encourage holders to voluntarily become compliant with unclaimed property reporting requirements. The program allows participants to remit past due unclaimed property without paying interest and penalties.
Participants in the Voluntary Disclosure Program are eligible for the waiver of interest and penalties, usually charged on past due properties.
No - As allowed by North Carolina General Statute 116B-60 (f1), any holder having two hundred fifty dollars ($250.00) or less to report, may remit such property without being assessed interest or penalties, and would not be required to obtain UPD's authorization prior to reporting.
Any company, organization, or entity in possession of past due unclaimed properties reportable to North Carolina, that is not currently under audit by the Unclaimed Property Division or one of our Audit Vendors is eligible to participate in the VDP. Holders currently under audit or that have been notified of an upcoming audit by the Unclaimed Property Division or one of our Audit Vendors may not be eligible to participate in the VDP.
Holders desiring to participate in the VDP should complete a Voluntary Disclosure Program Request Form. The completed form and required documents should be emailed to : voluntarydisclosureprogram@nctreasurer.com. A member of the Compliance and Audit section will contact you with more information.
Once a Holder has been determined to be a candidate for the VDP, UPD holds an opening conference with the Holder to determine the appropriate documents to send to the Holder. The Holder will have 90 days to complete and return their documentation to the Unclaimed Property Division for consideration of participation in the VDP. After the Holder's documentation has been reviewed and they are approved to complete the VDP, the Holder has 90 days to:
- Perform due diligence in accordance with NCGS § 116B-59
- File Annual Report(s) for each report year past-due unclaimed property is found, within ninety (90) days of the VDA approval date (date signed by UPD).
- Submit the full payment of past due unclaimed property.
The lookback period is ten years plus the dormancy period.
Once the self-review is done, the Holder will send the self-review to the Compliance Auditor who will then evaluate the self-review and make a recommendation to the Audit Manager. If the Compliance Auditor agrees with the Holder’s self-review, the Holder will perform due diligence and submit the reports to the State of North Carolina - Unclaimed Property Division.
Yes, an extension can be requested. However, extensions will only be granted for good cause.
No, participation itself will not increase your chances of being audited. There are multiple factors used in identifying audit candidates, including but not limited to; reporting history, presence of facilities in North Carolina and number of employees.
The Unclaimed Property Division reserves the right to conduct an examination of the Holder's books and records for all reporting periods covered under an Agreement, but would limit the examination period to within five years after the program requirements have been met.
Direct all additional reporting and filing inquiries to upreports@nctreasurer.com or by calling 919- 814-4200 and selecting Option 3.