[WSBARP] LLCs Now Mandated To Disclose Ownership Per The Corporate Transparency Act (Title LXIV of the NDAA, H.R. 6395)?

[Bryce Dille]

It appears that it is not effective until some regulations and some sort of uniform form is adopted by 2022

Bryce H. Dille
Dille Law, PLLC
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From: wsbarp-bounces at lists.wsbarppt.com <wsbarp-bounces at lists.wsbarppt.com> On Behalf Of Jean M. McCoy
Sent: Thursday, April 1, 2021 10:39 AM
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Subject: Re: [WSBARP] LLCs Now Mandated To Disclose Ownership Per The Corporate Transparency Act (Title LXIV of the NDAA, H.R. 6395)?


Rob, thanks for the heads up.  This sounds like something our mom and pop clients would never hear about, as many of them form on their own and don’t engage a lawyer.  Would love to see this as a CLE subject – maybe the business group would loan us one of their smart people and the CLE people could do a cross-training seminar.

It sounds like it would apply to any LLC, but it would be nice if there was a threshold ownership requirement – safe harbor for our little guys under a certain value.



Jean M. McCoy | Attorney at Law
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From: wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com> <wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com>> On Behalf Of Rowley, Rob
Sent: Thursday, April 1, 2021 7:30 AM
To: WSBA RPPT <wsbarp at lists.wsbarppt.com<mailto:wsbarp at lists.wsbarppt.com>>
Subject: [WSBARP] LLCs Now Mandated To Disclose Ownership Per The Corporate Transparency Act (Title LXIV of the NDAA, H.R. 6395)?

Any thoughts on this new Act and mandated reporting requirements for our small mom and pop real estate holding LLCs?
https://thefactcoalition.org/fact-sheet-a-brief-summary-of-the-corporate-transparency-act-of-2019-title-lxiv-of-the-ndaa-h-r-6395/

Good article from the Wall Street Journal as to the issues.
https://www.wsj.com/articles/buying-a-home-through-an-llc-is-not-as-anonymous-as-it-used-to-be-11617204363

I also found this interesting.
https://www.archerlaw.com/wp-content/uploads/2021/03/Pietrafesa-PowerPoint-on-Corporate-Transparency-Act-v-3.7.2021-for-general-public.pdf

Sounds like a new CLE.


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