Legislative Update: Proposed LLC Ownership Disclosure Requirements for Rent-Stabilized Properties

A bill recently passed by the New York State Senate could bring significant changes for property owners who hold rent-stabilized buildings in LLC form. Senate Bill S119 proposes expanded disclosure obligations in connection with annual rent registration filings submitted to the New York State Division of Housing and Community Renewal (DHCR).

Under the bill, any LLC submitting a rent registration to DHCR would be required to identify all “beneficial owners” of the company—defined broadly to include individuals who directly or indirectly own equity or exercise substantial control over the LLC. The bill would also require disclosure of each owner’s percentage interest.

This measure builds on the state’s ongoing efforts to promote ownership transparency, particularly in the housing sector. If the bill is approved by the Assembly and signed by Governor Hochul—who has previously backed similar legislation—it would become law and apply to LLCs that own rent-regulated housing accommodations across New York.

If you own or manage rent-stabilized property through an LLC, now is the time to evaluate how this potential law may affect your registration obligations and ownership disclosures.

Sandman Malin PLLC advises owners, investors, and managers of multifamily properties on regulatory compliance and rent registration requirements. Please contact us if you’d like to discuss how this legislation could impact your holdings.