On September 13th, 2019 the State of New York (“NYS”) passed legislation requiring full disclosure, on the TP-584 and NYC RPT forms, of all members of any Limited Liability Company (“LLC”) acting as a Grantor or Grantee, of a 1-4 family residential property within NYS. The legislation is effective Monday September 23rd, 2019, and any conveyance, with or without consideration, is within its scope. Due to the short notice of the effective date, it is unclear whether NYS recording offices will reject recordings not complying with the statute.
No officially approved forms have been promulgated as yet, but we believe that use of the attached form is sufficient for compliance. The form allows you to list the names, business addresses, Tax ID/Social Security numbers, and percentage of ownership of all members, managers, and any other authorized persons of the Grantor and/or Grantee LLC. If any such member, manager, or authorized person of the LLC is a partnership or business entity, the form must also list the names and business addresses of all shareholders, directors, officers, members, managers, and partners of such partnership or business entity. If any of those parties is a business entity, the form must list those names and business addresses, until full disclosure of ultimate ownership by natural persons is disclosed. If the Grantor or Grantee is a corporation, partnership, or other legal entity, the new legislation does not apply.
Feel free to contact us with any specific questions or concerns. Thank you.