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NAUPA Reporting: How Banks File Unclaimed Property Reports

9/22/2026

Every state that receives unclaimed property from a bank wants the same basic facts: who the owner is, where they live, what the property is, how much it is worth and when it went dormant. The National Association of Unclaimed Property Administrators (NAUPA) publishes a standard electronic file format so holders can deliver those facts in a structure every state can load. When people in deposit operations talk about "the NAUPA report" or "the NAUPA file," that is what they mean.

The format is the easy part to describe and the hard part to get right. This post explains the two versions of the NAUPA standard in use, the property type codes a bank uses most, how the annual reporting cycle fits around the file, and the checks to run before you submit.

What a NAUPA Report Is

A NAUPA report is an electronic holder report built to NAUPA's published layout. It is not a separate legal filing. The legal obligation to report comes from each state's unclaimed property statute; NAUPA's standard simply defines a common file structure that states accept, often alongside their own online reporting portals and forms.

Under the Revised Uniform Unclaimed Property Act, the 2016 model act from the Uniform Law Commission, a report must:

  • be signed by or on behalf of the holder and verified as to completeness and accuracy;
  • if filed electronically, be in a secure format the administrator approves;
  • describe the property;
  • for property worth $50 or more (other than traveler's checks, money orders and similar instruments), include the owner's name, last known address and Social Security number or taxpayer identification number where known or readily ascertainable;
  • for safe deposit box property, say where it is held and can be inspected, and any amounts owed to the holder;
  • give the date from which abandonment was measured;
  • state that the holder complied with the owner notice requirements; and
  • include anything else the administrator requires by rule.

Items under $50 may be reported in the aggregate under the model act, without owner names and addresses. States adopt their own versions of each of these rules, and some states add a signed verification form that travels with the electronic file.

The 2016 model act also says the administrator may not require a paper report, and that a holder may hire a third party to prepare it but remains responsible to the state for complete, accurate and timely reporting and for paying or delivering the property. That last point matters when a vendor builds your file: the bank owns the result.

The Two NAUPA File Formats

NAUPA II: fixed-width records

The long-established NAUPA standard, usually called NAUPA II, is a fixed-width text file. According to NAUPA's published specification:

  • The file is non-delimited ASCII, with each record separated by a carriage return and line feed.
  • Records use a 625-byte layout. The first byte is a record type code, and the remaining 624 bytes hold that record's fields.
  • Numeric fields are right-justified and zero-filled with an assumed decimal point; character fields are left-justified and space-filled.
  • Each field is marked mandatory (the file is rejected without it), required (supply it if known, usually because law requires it) or optional.

The record types are:

Code

Record

Contents

1

HOLDER

The reporting institution

2

PROPERTY

One item of property and its owner

3

PROPADD

Additional owners of a property

5

SECURITY

Securities information

6

TANGIBLE

Tangible property, such as safe deposit box contents

9

SUMINFO

Report totals

 

Codes 4, 7 and 8 are reserved. A file starts with a HOLDER record and ends with a SUMINFO record, and everything between belongs to that holder. A single file can carry several holder reports in sequence if each begins with its own HOLDER and ends with its own SUMINFO record.

NAUPA III: XML

NAUPA has published a newer standard, NAUPA III, which moves from fixed width to XML and comes with an XML Schema Definition (XSD) that lets holders validate a file before sending it. Version 1.1 is dated August 2025. NAUPA III reorganizes the data as a remittance that contains a holder, which contains one or more reports, each containing property records with owner details.

It also adds structured elements that were free text or missing in NAUPA II, including:

  • Due diligence dates: the date the statutorily required owner notice was first performed, and any supplemental notice dates.
  • Returned mail: the date a mailing to the owner was first returned as undeliverable, or an email bounced where electronic contact is authorized.
  • OFAC-blocked property: the legal authority under which property is blocked and, if available, the blocking date.
  • Safekeeping: box number, the date the box was drilled, the lease expiration date, fees such as drilling and unpaid rent, and an item-by-item inventory with codes for coins, currency, jewelry, papers and other categories.
  • Report types: annual remittance, audit, supplemental or correction, voluntary disclosure agreement and others.
  • Negative reports: a report element for holders filing that they have nothing to report, where a state requires or accepts one.

NAUPA's own guidance is explicit that holders should not mix versions and should check with each jurisdiction which version it accepts. States can also impose requirements beyond the XSD. Until every state you report to has moved, expect to produce more than one format.

NAUPA Codes Banks Use Most

Every property record carries a property type code. The codes tell the state what kind of property it is receiving, which drives its dormancy rules, owner search and claims handling. The table shows commonly used banking codes in both versions as published by NAUPA.

Property

NAUPA II

NAUPA III

Checking accounts

AC01

AC001

Savings accounts

AC02

AC002

Matured CD or savings certificate

AC03

AC003

Unidentified deposits

AC07

AC007

Cashier's checks (NAUPA III: cashier's, certified and registered checks on which the bank is directly liable)

CK01

CK001

Certified checks

CK02

CK001

Money orders

CK07

CK006

Traveler's checks

CK08

CK007

CD interest checks

CK16

CK008

Safe deposit box contents

SD01

SD001

Other safekeeping

SD02

SD002

 

NAUPA II also includes codes such as AC08 (suspense accounts), CK13 (vendor checks), CK14 (checks written off to income), CK15 (other outstanding official checks) and MS01 (wages, payroll and salary), along with retirement account codes. NAUPA III adds banking codes not found in the older list, such as payroll card accounts and failed electronic payments, and separates money orders and traveler's checks from bank-liable official checks to reflect the federal rule that sends those instruments to the state of purchase.

Use the code that reflects the nature of the property, not the account where it happened to be booked. A cashier's check that sat in a suspense account is still a cashier's check. Some states publish their own crosswalks or additional instructions on codes; follow them where they exist. Each state also maintains its own dormancy period by code, which is why the same code can be reportable in one state this year and another state three years later.

Relationship and owner type codes

Every property record also carries a relationship code (who must claim the property, such as an individual owner, joint owners, a custodian or an estate) and an owner type code. NAUPA II made both mandatory. Getting them wrong is a common cause of claim delays, because the state cannot tell who is entitled to the money.

The Annual Reporting Cycle for Holders

The file sits at the end of a cycle that starts months earlier. A bank reporting to several states runs one cycle per state, overlapping.

  1. Cutoff date. Each state measures dormancy as of a set date. The 2016 model act uses a report filed before November 1 covering the 12 months preceding July 1, with insurance companies on a separate spring date. New York's banking schedule uses a June 30 cutoff and a November 10 report; Texas uses a March 1 cutoff and a July 1 report.
  2. Pull every item that will be reportable to each state as of its cutoff, by property type.
  3. Due diligence. Send owner notices within each state's window and remove items whose owners respond.
  4. Build the file. Map system data to the NAUPA fields, assign property, relationship and owner type codes, and aggregate small items where the state allows.
  5. Run the state's or NAUPA's validation, reconcile totals and resolve rejects.
  6. Sign and submit. Complete any verification form the state requires and upload through its portal.
  7. Pay cash property by the method the state accepts and deliver securities and tangible property under its instructions.
  8. Clear and retain. Close reported accounts to the state on the core system and keep the cycle file.

Some states require or accept a negative report when there is nothing to report; others, such as New York for banks, tell holders not to send one but to keep a record of the review. Texas's holder page invites holders with nothing to report to file a negative report. Check each state.

If a deadline cannot be met, the 2016 model act allows a holder to request an extension before the due date, and to make a partial payment of the estimated amount to stop interest accruing on it. State versions vary.

Unclaimed Property Reporting Software and Vendors

Banks generally choose among three approaches:

  • State portals and spreadsheet templates for a small number of items in a few states.
  • Reporting software, often a module of the core system or a standalone package, that generates NAUPA files from account data, tracks due diligence and stores the cycle history.
  • Outsourced reporting, where a vendor runs mailings and files reports.

Whichever you choose, the bank remains responsible for the accuracy of what is filed. Before relying on a tool, confirm that it applies the bank's owner-generated activity rules, carries current dormancy periods for each state and code, supports the NAUPA version each state accepts, and keeps an audit trail of changes. Ask the vendor how it learns of state law changes and how quickly it updates.

Pre-Submission Checks

Before any file goes out, a reviewer other than the preparer should confirm:

  • Totals tie from the population run to the file's summary record, to the remittance amount and to the general ledger.
  • Each item belongs to the right state under the priority rules: owner's last known address first, the bank's state of domicile where there is no address, and state of purchase for money orders and similar instruments.
  • Codes are correct for property, relationship and owner type.
  • Dates are right: the dormancy start date, the due diligence date and, for securities and boxes, the dates the state asks for.
  • Taxpayer IDs and addresses are populated wherever known, because they drive the state's ability to return the money.
  • Responses were removed. No item for an owner who responded to due diligence is still in the file.
  • Blocked property subject to OFAC sanctions is handled under the state's and OFAC's instructions, not sent with the ordinary remittance.

Keep the whole package. The 2016 model act requires holders to retain report records for ten years after the later of the filing date or the last date a timely report was due, unless the state sets a shorter period by rule. The cycle belongs on the annual year-end bank compliance checklist, and it overlaps with information reporting work covered in our post on 1099 reporting for banks.

Who Should Be Trained

The people who build NAUPA files need to understand the accounts behind the data, not just the layout. Deposit operations staff should know how each account type works, how activity is recorded and where owner information lives. The Deposit Accounts and Services course is aimed at that account-level knowledge, and the bank operations and deposit compliance training pages list related courses. Definitions for terms used here are in the banking glossary for operations.

Next Step

List every state you reported to last year, and next to each write its cutoff date, report date, accepted NAUPA version and whether it wants a negative report. If any cell is blank or sourced from memory, confirm it on the state administrator's site before this cycle starts. For deposit staff who build the files, Deposit Accounts and Services covers the account side of the work.

Frequently Asked Questions

What is a NAUPA report?

A NAUPA report is an unclaimed property holder report built to the standard electronic file format published by the National Association of Unclaimed Property Administrators. It lists each item of property being reported, the owner's identifying details, the property type code, the amount and the dormancy date, in a layout states can load. The legal obligation to report comes from state law; the NAUPA format is the common structure most states accept for delivering it.

What is the difference between NAUPA II and NAUPA III?

NAUPA II is a fixed-width ASCII format using 625-byte records, each identified by a record type code such as 1 for holder, 2 for property and 9 for summary. NAUPA III, published by NAUPA with version 1.1 dated August 2025, uses XML with a schema file for validation and adds structured fields for due diligence dates, returned mail, OFAC-blocked property and safe deposit inventories. NAUPA advises holders to check which version each state accepts.

What are NAUPA codes?

NAUPA codes are standard property type codes that tell the state what kind of property is being reported. Banking examples in NAUPA II include AC01 for checking accounts, AC02 for savings, AC03 for matured CDs, CK01 for cashier's checks, CK07 for money orders and SD01 for safe deposit box contents. NAUPA III uses five-character equivalents such as AC001, CK001 and SD001, and adds new codes for property types not in the older list.

When are unclaimed property reports due?

Each state sets its own date. The 2016 model act sets a report before November 1 covering the 12 months before July 1, with insurance companies reporting in the spring. Actual state dates differ: New York's banking schedule calls for reports by November 10, while Texas requires reports by July 1. A bank reporting to several states will have several deadlines and should take each from the state's current guidance.

Do banks have to file a negative report?

It depends on the state. Some states require or accept a negative report confirming the holder has nothing to report; NAUPA III includes an element for one, and Texas invites holders with nothing to report to file one. Others, such as New York for banking institutions, tell holders not to send a negative report but to keep a record of their review. Check each state's instructions every year.

Can a bank outsource its unclaimed property reporting?

Yes, but not the responsibility. The 2016 model act allows a holder to contract with a third party to prepare its report, while keeping the holder responsible to the state for complete, accurate and timely reporting and for paying or delivering the property. Banks that use a vendor should confirm it applies the bank's activity rules and current state requirements, and should review files before they are submitted.