New Compliance Obligations for Real Estate Developers, Investors, Fund Sponsors

The Corporate Transparency Act creates a federal beneficial ownership registry for corporations, LLCs and “other similar entities.” The act creates new and unprecedented reporting obligations relating to entity structures commonly used in private real estate development. Colleagues Christian A. Buerger, David L. Miller, Andrew J. Weiner and Aaron R. Hutman discuss the recently enacted the Corporate Transparency Act (Act) in The Corporate Transparency Act and New Compliance Obligations for Real Estate Developers, Investors, Fund Sponsors and Others. Many aspects of the new law are unclear, having been left to subsequent regulations. Disclosure requirements will apply to new and existing entities. While confidentiality is generally mandated, there are exceptions. Fines and penalties, civil and criminal, are prescribed for a failure to comply.