Can DC claim the contents of unclaimed safe deposit boxes that the federal Comptroller of the Currency took over from defunct national banks?

Plain-English summary

When a national bank fails and goes into receivership, the federal Comptroller of the Currency takes possession of unclaimed contents of customers' safe deposit boxes. For decades there was no clear federal procedure for what happened to those contents if the depositor never came forward. In 1982, Congress fixed that with the Garn-St. Germain Depository Institutions Act. Section 1408 of Garn-St. Germain authorized states to take custody of the contents under each state's own abandoned-property law. If a state did not claim within twelve months, the property would escheat to the federal government.

DC's Department of Finance and Revenue Director Jeffrey Humber asked Corporation Counsel Inez Reid in May 1984 whether DC could claim the contents of safe deposit boxes that the Comptroller had taken over from closed national banks. Reid said yes. Three legal pieces fit together. First, federal banking law treats DC as a "state" for these purposes (12 U.S.C. § 215b). Second, DC's Uniform Disposition of Unclaimed Property Act (D.C. Law 3-160) presumes the contents of safe deposit boxes abandoned after ten years and gives DC the right to take custody. Third, federal preemption is not a problem because Garn-St. Germain expressly invites state claims.

The opinion timing was urgent. Garn-St. Germain set a federal cutoff of June 30, 1984 for state claims, after which the federal government could escheat the property. DC needed to act fast.

What this means for you

If you are a DC resident who had a safe deposit box at a national bank that failed

Your property may have been delivered to DC under this opinion's framework. DC's unclaimed property program is run by the Office of Finance and Treasury (the modern successor to the Department of Finance and Revenue). The Office maintains an online search at https://unclaimed.dc.gov where you can look up your name. There is no statute of limitations on claiming back your own property; it remains yours, just held in trust by DC.

To claim:
- Search the DC unclaimed property database with your name and any prior addresses.
- File a claim with documentation of identity and ownership of the original safe deposit box (old bank records, lease agreements, key receipts).
- DC will verify and return the contents.

If you are an heir, you need to provide proof of your relationship and the chain of inheritance.

If you are an estate attorney handling a decedent's affairs

When you inventory a decedent's assets, check the DC unclaimed property database. If the decedent had old safe deposit boxes at any national bank that closed (especially during the 1980s S&L era when many banks failed), the contents may have ended up with DC under this framework. The estate inherits the right to claim the property. There is no time limit on claiming.

If you administer DC's unclaimed property program

This opinion is the legal foundation for DC accepting custody of safe-deposit-box contents from the Comptroller of the Currency. Two operational points carry forward. First, when the Comptroller takes possession of contents from a closed national bank, DC has twelve months from the closure to claim or the property escheats federally. Second, on delivery, the Comptroller's liability is fully released (D.C. Code § 42-220(a)), and DC assumes responsibility for safekeeping and returning the property to lawful owners.

The reunification function (publishing names, mailing notices to last-known addresses) under D.C. Code § 42-219 is the core public-purpose justification for the abandoned-property regime. It is not just revenue.

If you are a banking lawyer or trust officer

Two principles to know. First, Anderson National Bank v. Luckett, 321 U.S. 233 (1944), held that state abandoned-property laws applied to national banks do not impair federal banking authority; the bank's obligation to pay deposits to those legally entitled is unchanged whether the legal entitlement runs to the original depositor or to the state as custodian. Second, with the Garn Act, Congress closed any remaining gap by expressly authorizing states (including DC) to claim. There is no longer a viable federal preemption argument against a state claim.

If you are an unclaimed-property professional in another state

DC's analysis here is portable. The Garn Act treats DC as a state and creates a uniform federal procedure. Your state's abandoned-property act and the federal twelve-month claim window operate the same way. The legal foundation traces back to Provident Institution for Savings v. Malone (1911) and Connecticut Mutual Life Insurance Co. v. Moore (1947), the Supreme Court's foundational unclaimed-property cases.

Common questions

Q: Why does the federal Comptroller hold safe deposit box contents at all?
A: When a national bank fails, the Comptroller of the Currency takes over as receiver. The Comptroller secures the bank's assets, including the contents of safe deposit boxes that customers have not retrieved. Until Garn-St. Germain, federal law was unclear about what happened to that property if the customer never came forward.

Q: How is "abandoned" defined for DC purposes?
A: Under D.C. Code § 42-215, contents of a safe deposit box are presumed abandoned if unclaimed by the owner for ten years or more from the date the lease or rental period expired. The presumption is rebuttable; the actual owner can always claim back.

Q: What happens if neither DC nor any owner claims within twelve months under the Garn Act?
A: The property escheats to the federal government. The owner's claim is barred. This was the urgency behind the 1984 opinion: DC needed to perfect its claim before the federal cutoff so the property could be administered under DC's reunification framework rather than federally escheated.

Q: Does DC keep the property forever?
A: No. DC holds the property in trust for the lawful owner. There is no statute of limitations on the owner's right to reclaim. DC publishes names and mails notices under § 42-219 to try to reunify owners with their property. Under modern accounting, DC may transfer the residual cash value to the general fund after a longer period, but the underlying obligation to return to the owner persists.

Q: Does this only apply to national banks?
A: The Garn Act covers national banks held by the Comptroller. DC's abandoned-property law (§ 42-215) is broader and applies to any safe deposit box held by any person in the ordinary course of business. State-chartered banks are subject to DC's law without need for the federal Garn framework.

Q: What was the deadline?
A: Garn-St. Germain's twelve-month claim window expired June 30, 1984. The May 25, 1984 opinion was issued to clear DC's claim before that deadline.

Background and statutory framework

Unclaimed-property law has two foundations. The states have historically held the right to claim abandoned property under sovereign escheat power, going back to English common law. The Supreme Court endorsed state custodial-escheat statutes in Provident Institution for Savings v. Malone, 221 U.S. 660 (1911), and refined the doctrine in Connecticut Mutual Life Insurance Co. v. Moore, 333 U.S. 541 (1947). For interstate property (deposits at multistate institutions), the Court fixed jurisdictional rules in Texas v. New Jersey, 379 U.S. 674 (1965), and Pennsylvania v. New York, 407 U.S. 206 (1972).

National banks created a federal-preemption question. Could a state's abandoned-property law reach deposits at a national bank? The Court answered yes in Anderson National Bank v. Luckett, 321 U.S. 233 (1944), and again in Roth v. Delano, 338 U.S. 226 (1949). The state's claim merely substitutes the state for the depositor; the bank's obligation to pay according to the law of the state remains the same.

DC enacted the Uniform Disposition of Unclaimed Property Act in 1981 (D.C. Law 3-160, codified at D.C. Code §§ 42-201 et seq. before later recodification). Section 115 (D.C. Code § 42-215) presumes safe deposit box contents abandoned after ten years. Sections 117 and 119 (§§ 42-217, 42-219) require holders to report and pay over abandoned property. Section 120(a) (§ 42-220(a)) releases holders from liability on delivery to DC.

For closed national banks, the federal piece was missing until the Garn-St. Germain Depository Institutions Act of 1982. Section 1408 (12 U.S.C. §§ 216 et seq.) authorized states to take custody of unclaimed contents of safe deposit boxes from closed national banks held by the Comptroller. Section 733(b)(1) directs the Comptroller to deliver to a state on proof of entitlement. Section 732(3) lets a state claim "under applicable statutory law, asserting a demonstrable legal interest in title to, or custody or possession of, unclaimed property." Section 733(c)(1) creates a twelve-month claim window, after which the property escheats federally.

12 U.S.C. § 215b (Section 20 of Pub. L. 86-230, 73 Stat. 465) defines "state" for national banking purposes to include DC. So DC qualifies as a state under Garn-St. Germain.

The retroactive operation of abandoned-property laws is well-settled. The 1954 Uniform Act applied to property abandoned before its enactment, with the only limit being claims time-barred between the holder and the original owner before the law took effect (Douglas Aircraft Co. v. Cranston; Country Mutual Insurance Co. v. Knight). For safe deposit boxes, the holder-owner relationship is bailment (Lussen v. Southern California Savings Bank), and a bailee's statute of limitations does not run until the bailee denies the bailment. So no statute of limitations bars the missing owners' underlying claims.

The opinion concludes that DC may file the Garn Act claim, the Comptroller must deliver the contents to DC, and DC will administer the property under § 42-219's reunification machinery (newspaper publication and mailings to last-known addresses) and hold the residual in trust subject to claim by lawful owners or heirs.

Citations and references

Statutes:
- Garn-St. Germain Depository Institutions Act of 1982, Pub. L. 97-320, 96 Stat. 1513, 12 U.S.C. §§ 216 et seq.; sections 732(3), 733(a)(1), 733(b)(1), 733(c)(1)
- 12 U.S.C. § 215b (DC as "state" for national banking law)
- DC Uniform Disposition of Unclaimed Property Act, D.C. Law 3-160; D.C. Code §§ 42-202, 42-215, 42-217, 42-219, 42-220(a)

Cases:
- Provident Institution for Savings v. Malone, 221 U.S. 660 (1911), foundation for state abandoned-property power
- Connecticut Mutual Life Insurance Co. v. Moore, 333 U.S. 541 (1947), beneficiary protections in custodial-escheat scheme
- Anderson National Bank v. Luckett, 321 U.S. 233 (1944), state abandoned-property law applies to national banks
- Roth v. Delano, 338 U.S. 226 (1949), same for liquidated national banks
- Security Savings Bank v. California, 263 U.S. 282 (1923), Contracts Clause does not bar custodial-escheat
- Texas v. New Jersey, 379 U.S. 674 (1965), and Pennsylvania v. New York, 407 U.S. 206 (1972), jurisdictional priority among states
- Travelers Express Co., Inc. v. Minnesota, 506 F. Supp. 1379 (D. Minn. 1981), federal-state harmonization in unclaimed-property statutes
- Douglas Aircraft Co. v. Cranston, 58 Cal. 2d 462 (1962); Country Mutual Insurance Co. v. Knight, 40 Ill. 2d 423 (1968), retroactivity of abandoned-property acts

License

This opinion is published by the Office of the Attorney General for the District of Columbia. Per the DC.gov terms of use, content is licensed under Creative Commons Attribution 3.0, which permits commercial use, redistribution, and modification with attribution.

Source

• Original PDF: https://oag.dc.gov/sites/default/files/2018-02/Opinion-July-2014-Comptroller-Currency.pdf

Original opinion text

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Oinutrumtnt nf t~t itlitrtrt nf <ttnlumhiu
OF.FICE OF THE CORPORATION COUNSEL
DISTRICT BUILDING
WASHINGTON.

D. C.

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IN REPLY REFER TO:

LCD:L&O:TB:gbt
(84-121)

May 25, 1984

OPINION OF THE CORPORATION COUNSEL
SUBJECT: Claim of the District of
Columbia to Certain Unclaimed
Property in the possession of
the Comptroller of the Currency

•

Mr. Jeffrey L. Humber, Jr.
Director
Department of Finance and Revenue
300 Indiana Avenue, N. W.
Washington, D. C•
Dear Mr. Humber:
This is in reply to your request dated May 4, 1984, for
an opinion of this Office regarding the District's claim to
certain unclaimed property in the possession of the Controller of
the Currency. It is my opinion that such property is subject to
the claim of the District. My reasoning follows.
I

INTRODUCTION

•

Section 1408 of the Garn-St. Germain Depository
Institutions Act of 1982, Pub. L. No. 97-320, 96 Stat. 1513
(1982), 12 U.S.C. secs. 216 et seq., (hereinafter referred to as
the "Garn Act"), authorizes States to take custody of the
contents of safe deposit boxes of closed national banks
(hereinafter referred to as "unclaimed property") in the
possession of the Comptroller of the Currency (hereinafter
referred to as the ·Comptroller·). Section 20 of an Act to amend
the national banking laws to clarify or eliminate ambiguities, to
repeal certain laws which have become obsolete, and for other
purposes, Pub. L. 86-230, 73 Stat. 465 (1959), 12 U.S.C. sec.
2l5b, defines ·state R to include the District of Columbia •
Section 733(b)(l) of the Garn Act expressly requires the
Comptroller to deliver unclaimed property to a state after
receiving proof therefrom that it is entitled to the property.

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Section 732(3) allows for states to claim the unclaimed property
" ••• under applicable statutory law, asserting a demonstrable
legal interest in title to, or custody or possession of,
unclaimed property."

II
THE ABANDONED PROPERTY LAW OF THE DISTRICT
OF COLUMBIA APPLIES TO THE CONTENTS OF SAFE
DEPOSIT BOXES HELD BY NATIONAL BANKS
Section 115 of the District of Columbia Uniform
Disposition of Unclaimed Property Act, D.C. Law 3-160, effective
March 5, 1981 (hereinafter referred to as the "District Act"),
D.C. Code, sec. 42-215 (1981), expressly presumes abandoned the
contents of unclaimed safe deposit boxes.
It states:

•

Except as provided in section 3 of an Act to
revise certain laws with respect to the liability
of hotels, motels, and similar establishments in
the District of Columbia to their guests,
approved December 8, 1970 (84 Stat. 1396; D.C.
Code, sec. 34-108), all personal property
tangible or intangible, held in a safe deposit
box or any other safekeeping repository in the
District by any person in the ordinary course of
business, which is unclaimed by the owner for ten
(10) years or more from the date on which the
lease or rental period on the box or other
repository expired is presumed abandoned.
Sections 117 and 119 of the District Act, D.C. Code,
secs. 42-217 and 42-219, require every person holding property
presumed abandoned to report such property to the Mayor, then to
pay it over. These provisions of the District's law apply to
property in the possession of the Comptroller.
Section 102 of the District Act, D.C. Code, sec. 42202, defines "holder" and "person" as follows:
(10)
"Holder" means any person whereever organized or
domiciled:
(A) In possession of property belonging to
another;
(B) Who is a trustee in case of a trust; or
(C) Who is indebted to another on an obligation •

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(16)
-Person- means an individual, business
association, government or governmental subdivision or
agency, public corporation, public authority, estate,
trust, 2 or more persons having a joint or common
interest, or any other legal or commercial entity.

Attached hereto as Exhibit A is a true and correct
copy of all provisions of the abandoned property law of the
District.

III
THE PURPOSE OF ABANDONED PROPERTY

LEGISLATION IS TO REUNITE MISSING OWNERS
WITH THEIR PROPERTY
Numerous cases have construed the operation and effect
of custodial unclaimed property legislation. All decisions have
concluded that one of the primary purposes is to reunite the
missing owner with the unclaimed property.

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In the first Supreme court case to review a state's
unclaimed property law, the court upheld the constitutionality of
Massachusetts' legislation reasoning as follows:
"The statute deals with accounts of an absent
owner, who has so long failed to exercise any
act of ownership as to raise the presumption
that he has abandoned his property. And if
abandoned, it should be preserved until he or
his representative appears to claim it; or
failing that, until it should be escheated to
the state. The right and power so to legislate
is undoubted.- Provident Institution for
savings v. Malone, 221 u.s. 660, 662 (1911).
Similarly the Supreme Court in considering the
provisions of New York's abandoned property law concluded:
-There is ample provision for notice to beneficiaries and for administrative and judicial
hearing of their claims and payment of same.
There is no possible injury to any beneficiary.Coririecticut: Mut:ual Life Insurance Co. v. M6ore~
333 u.S. 541, 547 (1947).

•

Numerous state courts have reviewed the provisions of
their custodial abandoned property legislation. For example, the
purpose of the 1954 Uniform Disposition of Unclaimed Property Act
has been explained as follows:

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-The objectives of the Act are to protect
unknown owners by- locating them and restoring
their property to them and to give the state
rather than the holders of unclaimed property
the benefit of the use of it • • • • - Douglas
Aircraft··cb. v. Cranston, 58 Cal. 2d 462, 463,
374 P.2d 819 (1962).
Accordingly, pursuant to section 118 of the District
Act, D.C. Code, sec. 42-219 the District in attempting to locate
the lawful owners of the unclaimed property will advertise their
names in a newspaper of general circulation and mail notices to
the missing owners.
IV
THE DISTRICT'S ABANDONED PROPERTY LEGISLATION
IS NOT PREEMPTED BY FEDERAL LAWS REGULATING
NATIONAL BAN~S

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Long ago the Supreme Court upheld the constitutionality
of state unclaimed property laws as applied to national banks.
In Arid~rsbnNati6n~l ~arik v. tuck~tt, 321 u.s. 233 (1944), the
Court reviewed Kentucky's abandoned property law and held:
"Under the statute the state merely acquires
the right to demand payment of the accounts in
the place of the depositors. Upon payment of the
deposits to the state, the bank's obligation is
discharged. Something more than this is required
to render the statutue obnoxious to the federal banking
laws. For an inseparable incident of a national
bank's privilege of receiving deposits is its
obligation to pay them to the persons entitled
to demand payment according to the law of the state
where it does business. A demand for payment of an
account does not infringe on or interfere with any
authorized function of the bank. In fact inability
to comply with such demands is made a basis in the
national banking laws for closing the doors of a
bank and winding up its affairs." Anderson, supra,
321 U.S. at 248, 249.
Subsequently the Supreme Court in the case of Roth v.
Delano, 338 U.S. 226 (1949), held that state abandoned property
legislation as applied to a liquidated national bank was
constitutional. Since Congress has in the Garn Act expressly
authorized states to claim the contents of safe deposit boxes in
the possession of the Comptroller, a contention of federal
preemption cannot be sustained •

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v
THE STATES HAVE THE EXCLUSIVE POWER TO
REGULATE THE DISPOSITION OF ABANDONED
PROPERTY
In the event that an owner fails to file a claim to the
unclaimed property within a twelve-month period, the Garn Act
purports to bar the claim of the owner. Thereafter, unless the
custody of the property is given to the District pursuant to the
claim made herein, the property will be escheated to the federal
government and the lawful owners will be deprived of their
property. See Garn Act, sec. 733(c)(1).
Only where the unclaimed property has resulted from
federal munificence, such as in the case of veteran pensions,
have the courts recognized a right on the part of tpe federal
government to claim the property of the recipient. See for
example, In re tiridqui~t'i"~st~t~, 25 Cal.2d 697, 154 P.2d 879,
cert. denied, 325 u.S. 869 (1944).

VI

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THE PROVISIONS OF THE LAW OF THE DISTRICT
APPLY TO CONTENTS OF SAFE DEPOSIT BOXES ROW
IN THE POSSESSION OF THE COMPTROLLER
Unclaimed property legislation has always been
construed to apply retroactively to property in existence at the
time of adoption of the legislation. The only limitation which
has been placed on the retroactive operation of such legislation
is that in most states the statutory provisions will not be
construed so as to revive claims on which the statute of
limitations as between the holder and the owner has expired.
In Security Savingi'Bank v. California, 263 u.S. 282
(1923), the Supreme Court held that application of California's
unclaimed property law to deposits more than 30 years old did not
violate the Contracts Clause in the Federal Constitution. The
Court reasoned that, "The contract of deposit does not give the
banks a tontine right to retain the money in the event it is not
called for by the depositor", 263 u.S. at 286.

•

Similarly in Anderson, National "Bank v. Reeve~, 293 Ky.
735, 170 S.W.2d 350 (1942), aff'd, 294 Ky. 674, 172 S.W.2d 575
(1943), aff'd sub nom. AndersoriNatiori~l 'Barikv. Luckett, 321
u.S. 233 (1942), the Kentucky abandoned property law was held to
be valid in its application to deposits in a national bank "made
both prior and subsequent to the effective date of the Act", 293
Ky. at 744 •
In Pennsylvariia v. New York, 407 U.S. 206 (1972), the
Supreme Court held that its 1965 ruling in texas v. New'JerSeX'

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379 u.s. 674 (1965), regarding which state could claim abandoned
property applied retroactively to money orders issued by Western
Union in 1930. The court then noted that, "Insofar as the
invocation of any provision of the Revised Uniform Disposition of
Unclaimed Property Act [1966] would be inconsistent with this
decree, the decree prevails", 407 U.s. at 215 n.8. Thus the
Court in addressing itself to the Uniform Act promulgated in 1966
necessarily assumed its provisions applied to property abandoned
30 years prior to adoption of the Act.
The 1954 Uniform Disposition of Unclaimed Property Act
provides a typical example of the retroactive operation of
abandoned property legislation. Section 2(d) of the Unform Act
presumes the abandonment of the contents of safe deposit boxes
which have been unclaimed for "more than seven years". Section
ll(g) requires the initial report be prepared as if the Act had
been in effect during a ten year period prior to adoption of the
Act. Several cases have construed these provisions to make all
existing abandoned property subject to the Uniform Act provided
only that the owner's claim to the property was not time-barred
on the effective date of the legislation. See, b6ti~1~s Aiidt~ft
Co. v. Cranston, 58 Cal. 2d 469, 374 P.2d 819, (1962) ("existing
abandoned property is subject to the Act"): Country "Mut.ua'!
trisut~riceCb. v. knight, 40 Ill.2d 423, 240 N.E.2d 612 (1968)
(Mexisting abandoned property subject to the Act") •
Congress intended that states would be entitled to
claim the "unclaimed property pursuant to existing abandoned
property laws whenever adopted. The Report of the Committee on
Banking, Housing and urban Affairs, United States Senate,
accompanying the Garn Act, provided:
"A state may assert a right to possession of
any unclaimed property during the twelve month
claim period if it has a law, whenever "adopted,
that permits it to take custody of such property.
Any state with such a law shall be deemed to have
provided adequate proof that it is entitled to such
property, which was removed from a closed national
bank located in that state, unless a claim by another
person or entity to such property is determined by
the Comptroller to take precedence. The Comptroller
is not expected to require a state to bring suit to
obtain possession or to provide further documentary
evidence of entitlement. All claimants, including
states, shall be required to comply with regulations
consistent with the above." (emphasis added)

•

Federal legislation intended to promote the return of
abandoned property to missing owners should be construed
consistently with the Uniform Act and other unclaimed property
legislation. Recently another federal act designed to facilitate

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the ~eposition of unclaimed property received judicial
consideration. In the case-of·riav~lei~~~pr~~s Co~ Iri6. v.
~iriri~~oti, 506 F.Supp. 1379 (D.Minn. 1981), aff'd, 664 F.2d 691
(8th eire 1981), cert. denied, 456 u.s. 920-(1982), the court
construed legislation which prescribed the rules by which states
could claim unpresented money orders.
The court stated that the federal law was:
"plainly designed to interact with the Uniform
Act.
It is presumed that a lawmaking body acts
with existing law in mind and that new statutes
will harmonize rather than conflict with existing
statutes." 506 F.Supp. at 1384.
VII
NO STATUTE OF LIMITATIONS BARS
THE CLAIMS OF THE MISSING OWNERS

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As discussed in Section VI, abandoned property
legislation applies to all obligations except those which are
time-barred as of the effective date of the law.
In the case of
the property now in the custody of the Comptroller, no such
impediment bars the claim of the missing owners •
The Garn Act, Section 733(a)(1), expressly allows all
claimants, including states, a period of twelve months within
which to file claims to the property. Thus Congress has
expressly established a period of limitations which will not
expire until June 30, 1984.
In the absence of such a provision
the result would be the same. The relationship between that of
the bank and the safe deposit box owner is that a bailee and
bailor. tuss~ri v. So. 'California Savings Bank, 133 Cal. 534, 65
Pac. 1099 ("depositary for hire"). See 10 Am.Jur.2d §47S.
Accordingly, the statute of limitations would not run until the
Comptroller denied the bailment and converted the property to his
own use, 8 Am.Jur.2d §30S. Accord, Memorandum of the Deputy
Corporation Counsel, Legal Counsel Division, "Application of the
District of Columbia Uniform Disposition of Unclaimed Property
Act," dated September 13, 1982 (Exhibit B).
VIII
UPON DELIVERY OF THE PROPERTY TO THE
DISTRICT, THE COMPTROLLER IS RELIEVED OF
ALL LIABILITY

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Section 120(a) of the District Act, D.C. Code, sec.
42-220(a), expressly relieves the Comptroller from all liability
for any abandoned property delivered to the state.
It states:

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upon the payment or delivery of property to the
Mayor, the District government assumes custody and
responsibility for the safekeeping of the property.
Any person who pays or delivers property to the Mayor
in good faith under this chapter is relieved of all
liability to the extent of the value of the property
so paid or delivered for any claim then existing or
which may arise thereafter or be made in respect to
the property.
IX
CONCLOSION

Based on the provisions of section 115 of the District
Act, D.C. Code, sec. 42-215, it is the opinion of the Office of
the Corporation Counsel that unclaimed property in the possession
of the Comptroller is subject to the claim. of the District.
Accordingly, such property shall be reported and delivered
pursuant to the requirements of sections 117 and 119 of the
District Act, D.Ci Code, secs. 42-217 and 42-219.
Sincerely,

•

~"3~~
Inez Smith Reid
Corporation Counsel

Attachments

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