Does customer contact include a customer accessing their account on-line or does the contact acknowledging knowledge of the account that is dormant have to be in writing or a transaction?

It will all depend on your specific State's escheat rules and regulations.

Our bank is an internet bank and covers all states. Do you know of any quick way to find all the differences?

Nothing for free that is up to date that I am aware of. Looks like digging into 50 sets of State law. For example, there are prescribed letters that must be mailed at specific times to customers in Texas.

Thanks. I'll ask our legal group to do that

When we have conversations with the states they do allow banks to consider someone accessing their account via the web; however they do require the access to consist of a PIN-Driven process. They also want to see regular access; so the customer accesses their account quarterly/monthly (even if no transactions); then the account is considered “active”. If over the 3 or 5 year period (depending on the state) the customer accessed the account only once; they would like you to send a Due Diligence Letter.

Please note IRA accounts have different rules.