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New York LLC Transparency Act: What Small Firms Must File With FinCEN vs. the State

The New York LLC Transparency Act, effective January 1, 2026, requires New York LLCs and foreign LLCs registered in New York to disclose beneficial ownership information to the New York Department of State — a state-level disclosure obligation that runs parallel to, but is distinct from, the federal Corporate Transparency Act's FinCEN reporting requirements. Small firms need to understand the differences between the two regimes and whether they qualify for any exemptions. This article maps the key distinctions.

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