Texas July 1 Filing Cycle, March 1 Cutoff & Comptroller VDA Representation
Texas operates on an unusual March 2 – March 1 cutoff period with a July 1 filing deadline and aggressive cross-matching against Texas franchise tax registrations.
Texas Statutory Dormancy & Compliance Schedule
| NAUPA Property Stream | Statutory Dormancy | Compliance Rule |
|---|---|---|
| Uncashed AP Vendor Checks (CK13) | 3 yrs | Texas provides no B2B exemption; vendor checks, customer credit balances, and commercial overpayments are reportable after 3 years of owner inactivity. |
| 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: By May 1 (60 days prior to July 1). |
| Gift Cards & Stored Value (GC / MS12) | 3 yrs (unless exempt stored value) | Unaddressed cards route to corporate domicile under 2nd Priority. |
| Securities & Dividends (SC01 / SC08) | 3 yrs | First-class mail (or electronic where consented) for items > $250 |
| Virtual Currency / Digital Assets (VC) | 3 yrs | Verify liquidation vs. native custodial transfer mandate. |
Key Texas Compliance Traps & Enforcement Risks
Texas Comptroller Voluntary Disclosure Agreement
Proactive multi-year disclosure prior to Comptroller audit notice waives 10% statutory interest and 5%–10% delinquent filing penalties.
Statutory Interest & Penalties: 10% per annum interest + 5%–10% late penalties. Negative Report Policy: Required for entities previously filing or notified by the Comptroller; standard holders with zero reportable property are not required to file unless requested.
Statutory Questions & Answers
Does Texas have a B2B exemption for vendor checks or credit memos?
No. Texas eliminated broad commercial exemptions and enforces reporting of aged B2B AP checks and AR credits after 3 years.
When is the Texas due-diligence mailing threshold triggered?
Holders must mail written due-diligence notices by May 1 for all reportable items valued over $250.