Gov Hochul Signs NY LLC Transparency Act

On December 23, 2023, Governor Hochul signed the New York LLC Transparency Act (the “Act”). While there is substantial overlap with the federal Corporate Transparency Act, as reported in this post, there are several differences. Among them is that the Act only applies to LLCs, and requires filings with the N.Y Department of State that do not entirely overlap with those required to be made with the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN). The most controversial difference, perhaps, is that the database formed by the filings will be semi-public. The effective date is January 1, 2025. Litigation, however, seems possible.