We recently discovered that we neglected to report the names of two individuals when we published the list of customers with accounts to be escheated. Should we publish them now? Or does it make any difference as we did not publish them by 9/1 as required.

Are they not otherwise disqualified for publication due to dollar amount or another reason? You operate out of New York? If you do not have an exemption, I would be contacting the NY Comptroller's Office and asking for guidance.

Well, we just figured out that the two accounts had a foreign address. So that disqualifies them. Thankfully.