The New York Limited Liability Company Transparency Act, as amended, became law in January 2024 and is scheduled to take effect on January 1, 2026 (the “NY LLCTA”). However, because the NY LLCTA references the federal Corporate Transparency Act (“CTA”), it is not clear whether the 2025 changes that FinCEN made to the final CTA Regulations (the “CTA Regs”) also change the NY LLCTA’s definition of Reporting Company.

New York’s definition of Reporting Company

A “Reporting Company” is required to file a beneficial ownership disclosure with the NY Department of State. The NY LLCTA provides that:

‘‘Reporting company” shall have the same meaning as defined in 31 U.S.C. § 5336(a)(11), as amended, and any regulations promulgated thereunder, but shall only include limited liability companies fo

See Full Page