Disclosure Requirements Under New York LLC Transparency Act

January 11, 2024 - Following enactment of the federal Corporate Transparency Act (the "CTA"), which established an unprecedented requirement in the U.S. to disclose to the federal government the beneficial owners of certain entities, on December 22, 2023, New York Governor Kathleen Hochul signed into law the New York LLC Transparency Act (the "NYTA"). The NYTA establishes a state-level reporting regime that would increase transparency of the ownership of certain limited liability companies ("LLCs"). The NYTA will take effect on December 21, 2024. As noted below, however, Governor Hochul's approval was subject to a "chapter amendment"¹ that New York State ("NY") intends to enact prior to effectiveness to address privacy concerns.