We just uncovered a problem with our automated dormancy indicator. Our CDs stopped reaching dormant status - we've now resolved that; however, we are past escheat timing for some of these. I can't see where the DOR rules address this scenario.

My instinct is to immediately get our due diligence letters out and just escheat this fall if we get no contact from the customers. Thoughts? Would anyone handle this differently?

Or I can call DOR...

Looks like I found the RCW. Appears we will be paying some interest...

Before you just automatically start to calculate interest for failing to escheat funds on a timely basis, you may want to review your customer's history with your bank to see if they had some form of contact with your bank during the dormancy period which, under WA law, would have taken the CD out of dormancy status.

I dealt with a similar situation for a CA bank many years ago. Under CA law, a customer's activity on any account will apply to all of their accounts. By going through the customer's entire relationship with the bank and all activity on other bank accounts (e.g., non-automatic deposits into and withdrawals from other accounts, providing a POA, changing privacy selections, adding a POD beneficiary), we were able to determine that nearly all of the so-called dormant CDs would not have been escheated. You should consult with your bank counsel to determine if this approach might help you.