A message to the States
from: Tom
Berger & Mike
Ryan
Operation Rightful Owner is a wonderful initiative that has the potential to
benefit millions of owners of unredeemed savings bonds while also compensating
States for their substantial efforts in coordinating the reunification process.
We personally support the concept, though we do have some concerns and suggestions
regarding the legislation and implementation. Below, we have outlined just a
few reasons why we believe APEARS must be one of the steps used to ensure the
success of this exciting and worthwhile effort.
As background, Cross Country Computer created APEARS,
the Abandoned Property Escheat Assignment & Reporting
System. As you may be aware, APEARS has been used with
great success in support of some of the largest unclaimed
property filings in history. APEARS helps ensure that
millions of dollars are delivered to the proper state,
as opposed to being remitted to either a state of incorporation
as unknown, or to incorrect states. In fact, we know of
no other automated system in existence with similar capabilities,
which means that APEARS is the only proven solution capable
of supporting Operation Rightful Owner to the exacting
standards that will be required. We have highlighted some
key points below and we will share some alarming examples
in future press releases to this site.
Fact: The earliest bonds were issued more than 60 years
ago, which means the addresses will be old and in poor
condition
(Click here to View Examples). This combination
of old invalid address information, missing address data
and ownership terminology including custodial and trust
references, will make traditional data parsing and address
verification tools insufficient. This means that there
is a very real risk that many records will be delivered
to the wrong state, or not even delivered at all. APEARS
was designed specifically to review and repair addresses
with these characteristics, and has a proven track record.
No other automated solution has ever demonstrated comparable
performance. APEARS will increase the number of bonds
assigned to each State and deliver those records in better
condition, which in turn will translate to lower expenses
for the States, higher reunification rates, and more lucrative
performance-based success fees.
Fact: If these old addresses are not handled properly,
in accordance with section (b)(3) of HR 5984, the registered
owner’s address of record may not meet Government
Auditing Standards for relevance, competence and sufficiency.
This in turn means that States will never have the opportunity
to receive and attempt to reunite bond proceeds with their
rightful owners. This would be bad for our citizens and
bad for the States. APEARS is uniquely able to assign
confidence codes to each address and provide supporting
documentation to substantiate every single determination.
In addition to improved compliance with Government Auditing
Standards and ensuring that more property gets accurately
routed to each State, using APEARS will significantly
reduce the costs of managing the overall program.
Fact: It is reasonable to expect that there will be multiple
unredeemed bonds belonging to a common owner. HR 5984
has no provision for this. APEARS has the ability to link
bonds to a common owner, even in cases where there may
be subtle differences in the owner’s address or
ownership designation. This can save States money by reducing
costs associated with location, mailing, postage and claims
processing. At the same time, this APEARS feature will
enable more bond proceeds to be returned to each owner,
which will generate additional fees for the States as
well. For example, if an owner makes a claim for a single
bond, they can be provided claim forms for related bonds
at the point of processing. It is also worth noting that
there will be bonds with multiple owners. APEARS can identify
multi-owner accounts and differentiate among ownership
types to help States understand which parties are able
to execute claim forms, which will help further reduce
the potential for fraudulent or misdirected claims.
In summary, we believe that to truly make Operation Rightful
Owner an unqualified success, APEARS should be used.
With such a high profile initiative, the States’ public
relations implications stemming from misdirected bonds
or incorrectly paid claims could be disastrous if APEARS’ best
practices standards are not applied. We would welcome
an opportunity to share our thoughts with you in greater
detail. If you have any questions, or would like to
schedule a time to speak, please feel free to contact
either one of us.
Thank you.
Thomas J. Berger
Phone: (631) 231-4200 x4214
Email: TBerger@OperationRightfulOwner.com
Michael Ryan
(718) 809-9449 – Mobile
Email: MikeR@OperationRightfulOwner.com
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