New Jersey Extends Time for Unclaimed Property Data Collection


As we noted in our July 7, 2010, Legal Alert, New Jersey recently enacted significant changes to its unclaimed property laws related to stored value cards (which include gift cards). The New Jersey Treasury Department has once again delayed the compliance date mandating the collection of consumer information associated with stored value cards until October 1, 2010.


While many of the provisions of the new law are problematic (See July 7, 2010, Legal Alert), section 5(c) requires a change in business practice of a card issuer or vendor—they must obtain the name and address of the purchaser or owner of each card issued or sold and, at a minimum, maintain a record of the Zip Code of the owner or purchaser. On July 1 (the initial effective date), the New Jersey Treasurer released its first announcement stating that issuers were exempted from the requirements of section 5(c) until September 1, 2010. On August 26, the Department released Treasury Announcement FY 2011-02, further extending the exemption from compliance with section 5(c) through October 1, 2010. The Treasury Department indicated that it needs to review current processes, technologies and reporting practices, and develop specific industry guidance.

Please see full alert below for more information.

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Sutherland Asbill & Brennan LLP on:

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