My company processes small rebate checks for a number of our clients. They write the rules, we open an account with their name on it, they fund the account, and we are charged with receiving and distributing the funds based upon the program guidelines. When the program is over any undistributed funds are returned to the client and you would hope all the small checks would be cashed. The reality is that two years later there are lots of small checks outstanding and we are left with the dilemna of closing the account and returning the outstanding balance to the client, or turning them over to the state as unclaimed property.
What is the appropriate way to handle?
If the recipient locates their check in a random desk drawer several years down the road, they will see our client's name on it. If the recipient has the original paperwork that comes with directions for how to obtain their rebate, the contact information will be for our company. Who they reach out to and who they expect to make good on these outstanding payments is a bit dependant on how they identify what is outstanding.
My preference is to refund the monies to our client with a list itemizing who got what so they can deal with it later. Is that ok to do as far as the states are concerned?
