Customer has other “Active” accounts or CIF “date last contact” is more current than 3 years
Update Escheatable account and other related accounts date last contact to = date last active or date last contact. (FDIC rules – Claim one Claim all concept)
Remove from Escheat status.

This is our process for activating accounts and we do not require any paper documentation as the maintenance performed shows on a system audit report and is completed by an particular department personnel as part of their common job duties.

Is there any audit requirements that would dictate the need for a paper trail for the "Claim one Claim all concept"?

What does the FDIC have to do with escheat? Escheat is a State law.

You need to refer to (765 ILCS 1026/15-210) Sec. 15-210.


(f) If the apparent owner has another property with the holder to which Section 201(6) applies, then activity directed by an apparent owner in any other accounts, including loan accounts, at a financial organization holding an inactive account of the apparent owner shall be an indication of interest in all such accounts if:

(A) the apparent owner engages in one or more of the following activities:



(i) the apparent owner undertakes one or more of the actions described in subsection (b) of this Section regarding any account that appears on a consolidated statement with the inactive account;



(ii) the apparent owner increases or decreases the amount of funds in any other account the apparent owner has with the financial organization; or



(iii) the apparent owner engages in any other relationship with the financial organization, including payment of any amounts due on a loan; and



(B) the foregoing apply so long as the mailing address for the apparent owner in the financial organization's books and records is the same for both the inactive account and the active account.