Establish the account's current status with the bank
Obtain a current statement or bank confirmation and verify the legal account holder. Record the balance, currency, account status and last customer-initiated activity. An account absent from the daily dashboard may still exist, accrue charges or require a response to bank notices. Do not remove it from the accounting register because nobody uses it regularly.
The OCC explains that inactive accounts can become subject to state abandoned-property processes and that notices may tell the owner how to respond. The applicable period and treatment depend on state law and the facts. Read the actual notice and contact the bank promptly rather than relying on a remembered universal dormancy deadline.
References: OCC: Inactive accounts and abandoned property
Reconcile the balance and identify its purpose
Collect missing statements and reconcile fees, interest and any unexpected activity. Compare the bank balance with the ledger and investigate differences. If the account was used for collateral, a reserve or a particular contract, retrieve the relevant agreement before deciding that the balance is available to transfer.
Ask the finance owner why the account remains open. It may support a legitimate contingency, a remaining refund or an infrequent obligation. Record that purpose and the review date. If no one can explain the account, investigate its origin and legal ownership rather than assigning a new purpose after the fact.
Check user permissions and recovery contacts. Former employees can remain associated with an account that has escaped routine access reviews. Use the bank's authorized process to update records and preserve individual accountability.
Choose retention or closure with explicit responsibilities
If the account will stay open, name the person who reviews statements and notices, confirm the bank's activity requirements and document how the account supports the business. Include any minimum-balance or service costs in the decision. Do not make artificial transfers solely because someone assumes they reset every legal dormancy rule; confirm what the bank requires.
If closure is appropriate, review outstanding payments, expected receipts and any contractual restrictions first. Follow the bank's process and obtain final evidence of the balance transfer and closure. Retain the account in the historical register with a closed status so earlier transactions remain traceable.
For a balance already transferred to a state, use the relevant official unclaimed-property process and establish the company's entitlement. The FDIC describes contacting the institution and, where appropriate, the state to locate old funds. Keep claims and confirmed recoveries separate in the ledger.
References: FDIC: Finding a lost bank account
Prevent the account from disappearing again
Add low-activity accounts to the same statement-completeness review as the main operating accounts. Use a frequency proportionate to the activity and risk, while making bank notices visible promptly. A quarterly management review does not replace responding to a notice with an earlier deadline.
Update contact details after office moves, ownership changes or staff departures. Confirm that electronic notices go to an actively monitored company address. Keep bank correspondence in an accessible company record rather than only in the mailbox of the person who originally opened the account. Record which role receives paper mail as well, particularly when the account's registered address differs from the operating office.
At the next review, verify that the retention decision still holds or that closure was completed. A dormant-account review should leave a supported balance, a clear business purpose or closure record, and a named person responsible for any remaining action.
Sources
Requirements and product details can change. Check the linked guidance for the facts that apply to your situation.
Related reading
Need help with this work?
General information, not personalized accounting, tax, legal, or investment advice. Have the appropriate qualified professional review decisions that depend on your circumstances.