March 21, 2023 - The California Voluntary Compliance Program (VCP) allows companies to come forward and self-report past-due unclaimed property in exchange for abatement of penalties and interest. Recently, Controller Cohen released updated instructions for participants.

Under California law, holders with dormant liabilities must report and remit them to the state. The VCP provides significant benefits for companies, as failure to timely report unclaimed property can result in substantial penalties and interest or even a costly audit.

Benefits

• Huge savings for organizations with operations, customers, or vendors in California
• Holders can avoid audits through the VCP

“This is a rare opportunity for holders to come into compliance in a state that historically assesses interest and penalty for past due property,” said Eric Mauldin, Managing Director at Citrin Cooperman. “We highly encourage companies to consider California’s Voluntary Compliance Program.”

Eligibility

It's important to note that there are eligibility requirements for the VCP. To qualify, your business cannot:

• Currently be under audit
• Be subject to a civil or criminal investigation
• Have unpaid interest assessment for the previous five years

This is an ongoing program. Businesses that cannot meet the due dates for the current reporting season can still apply to the VCP but will follow due dates for future report years.

Important dates for the upcoming report year

• July 31, 2023: Required training completed
• September 30, 2023: Due diligence completed
• Before November 1, 2023: Notice Report submitted
• June 1-15, 2024: Remit Report and remittance submitted

The California Voluntary Compliance Program creates a critical opportunity for businesses with unclaimed property on their books.

If your organization is concerned about compliance and believes there is past-due property owed to the state of California, contact Eric Mauldin to learn more about the VCP.