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Voluntary Compliance Program

Are you holding unclaimed property that has not been reported? Good news! Under the California State Controller’s Voluntary Compliance Program (VCP) you may qualify for a waived interest assessment. Approved and enrolled holders that fulfill all program requirements, including completing a training program and meeting reporting deadlines, will be eligible for waived interest on past-due unclaimed property reported under the program.

It is the mission of the California State Controller’s Office (SCO) Unclaimed Property Division to reunite lost and abandoned property with its rightful owner, safeguard those properties from being used by private interests for personal gain, relieve holders of the expense and liability associated with holding unclaimed property, and provide a central source for owners to locate and claim their property. The purpose of the VCP is to develop a community of compliance by enabling and incentivizing holders of unclaimed property, including first time filers, to come into compliance with California’s Unclaimed Property Law (Code of Civil Procedure [CCP] Section 1500 et. seq.) without examination or penalty. The Controller further seeks to enable holders to report timely and consistently in future years.

The VCP is an ongoing program. Holders may apply at any time. SCO will accept applications throughout the year and provide due dates if enrolled.

Eligibility Criteria

A holder is eligible to participate in the VCP if, at the time of application, they:

• Are not the subject of an unclaimed property examination, or have not received notification of an upcoming examination;
• Are not the subject of a civil or criminal prosecution involving compliance with the Unclaimed Property Law;
• Do not have unpaid or unresolved interest assessments from within the past five years; and,
  • Holders with any outstanding interest assessment at the time of application may refile an application after resolving the outstanding interest assessment.
• Have not had interest waived under the VCP within the past five years, or are applying to resolve unclaimed property related to an acquisition or merger. 

VCP Application Steps:

Application Step 1: Determine if your business may have unclaimed property that is past due. If so, you can apply for and receive a waiver of interest if you report, remit, and complete all requirements within the timeframe prescribed.

Application Step 2: Submit a complete and signed VCP Application (VCP 01) form. Be sure to provide full responses to all parts of the application, including:

• Estimated value of inactive properties and accounts in your records;
• Timeframe under which you can submit your Notice Report; and,
• Staff members who will attend training and submit reports.
  • Note: Businesses with only one employee are eligible to be enrolled and only need to send one person to training.

Application Step 3: SCO will review the holder’s eligibility for enrollment and inform the applicant of approval or denial. If approved, SCO will provide the enrolled holder with a confirmation of enrollment letter and Voluntary Compliance Program Requirements (VCP 02) form with due dates.

If you have questions about submitting a VCP Application (VCP 01) form, contact the Outreach and Compliance Unit at UPDHolderOutreach@sco.ca.gov or (916) 464-6088.

VCP Participation and Completion Steps:

VCP Step 1: Holder trainees register for and attend a 2-hour online training. The training includes a detailed overview of California’s Unclaimed Property Law, how to report, and the requirements of VCP participation. Trainees must participate in polls and quizzes to demonstrate an understanding of the material presented for the training step to be completed.

VCP Step 2: Review books and records from at least the previous 10 years for unclaimed property (or less if business has been in operation fewer than 10 years). You may start this step before submitting an application if doing so will enable you to conduct a full and complete review of your books and records.

VCP Step 3: Send Due Diligence notices to owners whose property you have determined is reportable as unclaimed no less than 30 days prior to submitting the Notice Report.

VCP Step 4: Submit a Notice Report by the assigned deadline using the Holder Reporting Portal. The Notice Report can be submitted earlier than the assigned due date as long as all previous steps have been completed.

VCP Step 5: Respond to owner inquiries received from pre-escheat letters sent to owners by SCO after you submit your VCP Notice Report and before your Remit Report is due.

VCP Step 6: Submit a Remit Report using the Holder Reporting Portal and remit property between 7 and 7 ½ months after submitting the Notice Report. SCO will notify you of your Remit Report due date on the Holder Remit Reminder Letter (14F) sent after your Notice Report has been accepted.

For more information about program requirements and qualifications, please consult our VCP Notice to Holders as well as Code of Civil Procedure Section 1577.5. Subscribe to our email ListServ to receive future updates.