New Requirements for TP-584 and NYC RPT Forms (New Tax Law Section 1409)

On September 13, 2019 the governor signed legislation that changes what information must be included with TP-584 and NYC RPT forms that accompany deeds that are being recorded, where a limited liability company (LLC) is the Grantor and/or the Grantee.

This legislation amends Tax Law § 1409 (TP584 form) and NYC Admin Code § 11-2105 (RPT form) and applies to all such deeds that are recorded on or after Monday, September 23.

The legislation affects deeds conveying title to residential real property containing 1- to 4-family dwelling units where the Grantor and/or Grantee is an LLC.

As required by the legislation, the TP584 and RPT form for the deed must now be accompanied by a document which lists the names and business addresses of all members, managers, and any other authorized persons of the Grantor and/or Grantee LLC. If any member, manager, or authorized person of the LLC is a partnership or business entity, the document must also list the names and business addresses of all shareholders, directors, officers, members, managers, and partners of such partnership or business entity. If any of those parties is a business entity, again, it must list the names and business addresses of the interested parties of that partnership or business entity until full disclosure of ultimate ownership by natural persons is achieved.

No official form has been made available yet. Until an official form is promulgated and distributed, we suggest that you have the appropriate form below completed at or prior to closing.

Sample Disclosure Attachment to RPT

Text of 2019 New York Senate Bill No. 1730, New York Two Hundred Forty-Second Legislative Session

Forms, content, and details provided by Fidelity National Title Insurance Company.