New Disclosure Requirements for an LLC when filling the TP-584
On September 13, 2019, the New York State Legislature enacted, and the New York City Council has adopted nearly identical provisions which amends Tax Law Section 1409(a) and adds a new subdivision to Section 11-205 of the New York City’s Administrative Code, respectively.
The provisions require that for the purchase or sale of residential real property containing 1 to 4 family dwelling units by an LLC to now include information on the ownership of the LLC for all deeds recorded on or after September 23, 2019. If any such member, manager or authorized person is also a business entity, then the names and business addresses of the shareholders, directors, officers, members, partners, etc. must also be disclosed until ultimate ownership by a natural person is achieved. This requirement also applies to no consideration conveyances. The legislation stated: “The information concerning the ownership of the LLC shall not be deemed an unwarranted invasion of privacy under Article Six of the Public Officers law.”
Until such time that the TP-584 forms have been amended, Benchmark Title Agency will require an affidavit setting forth the names and business addresses of all LLC members when insuring residential real property containing 1 to 4 family dwelling units.
Benchmark Title Agency, LLC