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Cal. Civ. Proc. Code (CCP) § 1500 et seq. · California State Controller's Office (SCO)

California Two-Step Filing Cycle, AB 466 FTB Disclosures & AB 2280 Voluntary Compliance

California enforces an automatic 12% annual interest assessment on late unclaimed property under CCP § 1577 and now cross-checks corporate compliance directly on Franchise Tax Board returns via AB 466.

Deadline: Before Nov 1 (Notice) / June 1–15 (Remit) Cutoff: June 30 (general corporate) No Statutory B2B Exemption Zero Report: Conditional

California Statutory Dormancy & Compliance Schedule

NAUPA Property StreamStatutory DormancyCompliance Rule
Uncashed AP Vendor Checks (CK13)3 yrsCalifornia provides no general B2B exemption; commercial AP checks and AR credit balances with California-addressed payees are reportable after 3 years of inactivity.
Payroll, Wages & Commissions (MS01)1 yrNever B2B exempt; applies to employee final & bonus checks.
AR Credit Balances & Overpayments (MS09)3 yrsWrite-offs to income do not extinguish reporting obligation.
Customer Refunds (MS05)3 yrsDue diligence window: 6–12 months prior to Notice Report (Nov 1).
Gift Cards & Stored Value (GC / MS12)Exempt (most open/closed loop)Unaddressed cards route to corporate domicile under 2nd Priority.
Securities & Dividends (SC01 / SC08)3 yrsFirst-class mail (electronic option where consented)
Virtual Currency / Digital Assets (VC)3 yrs (native delivery)Verify liquidation vs. native custodial transfer mandate.

Key California Compliance Traps & Enforcement Risks

AB 466 Franchise Tax Board Return Questions California Form 100, 100S, 100W, and 565 ask whether the business previously filed unclaimed property reports with the SCO, the date of the last filing, and total remitted—feeding direct audit leads to the Controller.
Two-Report Annual Architecture (Notice vs. Remit) Unlike single-filing states, California requires a Notice Report (no payment) before November 1, followed by SCO owner mailings and a final Remit Report with payment between June 1 and June 15.
12% Statutory Interest Without VCP Protection Submitting past-due items outside AB 2280 triggers automatic 12% per annum interest (non-discretionary under CCP § 1577) from the year each check or credit originally became reportable.
Prior 5-Year Waiver Disqualification Holders remain ineligible for AB 2280 VCP if currently under SCO examination, notified of an audit, or granted an interest waiver within the past five years.

California Voluntary Compliance Program (VCP — AB 2280)

10-year lookback; mandatory SCO holder training; 100% waiver of the statutory 12% annual interest if not under audit or granted a waiver within the prior 5 years.

Statutory Interest & Penalties: 12% per annum mandatory statutory interest (CCP § 1577) from original due date. Negative Report Policy: Not mandated for non-financial holders with zero property, though prior filers and AB 466 tax return respondents face strict cross-agency scrutiny.

Related Side-by-Side Decision Comparisons

Compare Alternatives California AB 2280 VCP vs. Direct SCO Past-Due Filing (12% CCP § 1577) →

Statutory Questions & Answers

Can we just pay past-due California checks on our next Notice Report without applying for AB 2280?

Filing delinquent years directly on a standard Notice Report exposes the company to automatic 12% annual interest under CCP § 1577. Enrolling in AB 2280 VCP before filing waives that 12% interest.

Are gift cards escheatable in California?

Most retail gift certificates without expiration dates or dormancy fees are exempt from escheatment in California under CCP § 1520.5, subject to statutory conditions.