Delaware scheduled another round of VDA invitation letters, mailing the first of these on or about Aug. 14, 2026. Companies receiving an invitation should act quickly because the 90-day period to respond runs from the date on the letter, not when the appropriate personnel within the organization receive it.
Crowe observation
The latest mailing continues Delaware’s active use of the VDA program to address potential unclaimed property noncompliance and puts additional emphasis on evaluating the entities and property types that could be implicated before deciding whether to enter the VDA program or proceed toward examination.
Delaware uses VDA invitations, verified report notices, and examinations as part of its unclaimed property compliance and enforcement activity. A company receiving a VDA invitation generally has 90 days to respond before it can be referred for examination.
The VDA program gives invited companies an opportunity to evaluate and resolve potential unclaimed property liabilities outside of a traditional state examination process. Delaware also offers an expedited examination process as an alternative for certain holders. The appropriate path depends on a company’s reporting history, available records, organizational structure, potential exposure, and other facts.
Timing is particularly important because the 90-day period begins when the state mails the invitation. Time spent moving the notice from a registered office, plant, mailroom, or other location to tax, legal, finance, or unclaimed property personnel does not extend the deadline.
A company that receives an invitation should preserve both the letter and envelope and confirm the mailing date immediately. Establishing the applicable deadline at the outset allows the organization to determine how much time remains for its substantive review.
Companies should identify the entities and property types that might be affected rather than focus only on the entity named in the invitation. The review should consider the organization’s legal entity structure, prior unclaimed property reporting, historical transactions, available books and records, and potential exposure. Identifying this information can be particularly important for organizations that have undergone acquisitions, reorganizations, mergers, or other changes that could affect which entities hold historical liabilities or records.
The invitation presents a decision between available compliance paths. A recipient can evaluate participation in Delaware’s VDA program, request an expedited examination, or take no action and risk referral to the state escheator for examination.
Crowe observation
The recent mailing reinforces the importance of internal controls over state correspondence. Organizations with numerous legal entities or locations should have procedures for recognizing Delaware unclaimed property notices and escalating them promptly.
Companies receiving a Delaware VDA invitation should promptly review the letter and assemble the appropriate company team, including personnel from tax, legal, finance, and unclaimed property, and consult with their unclaimed property adviser to assess potential exposure and next steps.
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