M.G.L. c. 200A · Massachusetts Dept. of the State Treasurer — Unclaimed Property Division
Massachusetts Tier 2 B2B Exemption Split & Mandatory November 1 Filings
Massachusetts exemplifies the Tier 2 B2B trap: AR credit balances between businesses are exempt, yet uncashed AP vendor checks remain strictly reportable.
Deadline: November 1
Cutoff: June 30
Tier 2 — Credit Balances Only
Zero Report: Mandatory
Massachusetts Statutory Dormancy & Compliance Schedule
| NAUPA Property Stream | Statutory Dormancy | Compliance Rule |
|---|---|---|
| Uncashed AP Vendor Checks (CK13) | 3 yrs | Massachusetts exempts B2B credit balances/overpayments between businesses, but uncashed B2B AP vendor checks REMAIN 100% REPORTABLE. |
| Payroll, Wages & Commissions (MS01) | 1 yr | Never B2B exempt; applies to employee final & bonus checks. |
| AR Credit Balances & Overpayments (MS09) | 3 yrs | Write-offs to income do not extinguish reporting obligation. |
| Customer Refunds (MS05) | 3 yrs | Due diligence window: 60 days prior to November 1. |
| Gift Cards & Stored Value (GC / MS12) | Exempt (qualified gift cards) | Unaddressed cards route to corporate domicile under 2nd Priority. |
| Securities & Dividends (SC01 / SC08) | 3 yrs | First-class mail for items >= $100 |
| Virtual Currency / Digital Assets (VC) | 3 yrs | Verify liquidation vs. native custodial transfer mandate. |
Key Massachusetts Compliance Traps & Enforcement Risks
Confusing Tier 1 (OH) with Tier 2 (MA)
Controllers often omit Massachusetts uncashed AP checks thinking 'B2B is exempt'—leaving the firm exposed to 12% interest on every uncashed vendor check.
$100 Due Diligence Threshold & Mandatory Zero Report
Massachusetts sets its due diligence mailing threshold at $100 (higher than the $50 norm) while requiring mandatory annual zero reports.
Massachusetts Treasury Voluntary Disclosure
Self-audit resolution waiving 12% statutory interest for holders remediating uncashed AP checks and wages prior to audit.
Statutory Interest & Penalties: 12% per annum interest + $500+ penalties. Negative Report Policy: Mandatory annual negative report required for businesses incorporated or active in Massachusetts.
Statutory Questions & Answers
Are uncashed AP checks to corporate vendors exempt in Massachusetts?
No. Massachusetts's B2B exemption applies to credit balances only—uncashed AP vendor checks must still be reported after 3 years.
What is Massachusetts's interest rate on late filings?
12% per annum under M.G.L. c. 200A § 12.