A NY LLC transparency checklist for accountants
An accountant can organize the record and deadline without turning a legal classification question into an accounting conclusion.
What the official record says
Section 1106 incorporates federal definitions for beneficial owner, reporting company, exempt company, and applicant. Section 1107 then assigns the disclosure, attestation, 30-day, transition, confidentiality, and annual-statement rules. This structure means the bookkeeping file may contain useful entity and ownership facts without answering every statutory element. The owner’s identification number, date of birth, and home address belong in the state filing flow, not in a general intake form.
What to check on the document
Build the workpaper around sources. Each answer should point to the DOS record, organizational document, ownership ledger, or client representation that supports it.
- Save the DOS formation or authority record and calculate the statutory deadline from that filing date.
- List the exact exemption text and the client fact supporting each element, with unresolved elements marked for counsel.
- Keep sensitive beneficial-owner identifiers outside the worksheet and have the owner complete them in the DOS portal.
How to use the result
For an annual client cycle, retain the state confirmation and compare ownership, principal-office address, and exemption status before the next filing. A prepared checklist can reduce missing facts and repeated requests. It does not authorize the preparer to choose a contested exemption or sign the owner’s attestation. The accountant can hand the clean issue list to counsel without rebuilding the chronology.
The worksheet maps the facts you provide to the words of LLC Law §1107 and marks any grey box for counsel. It does not decide a hard legal question. The filing belongs in the Department of State portal under the LLC owner’s control, with sensitive owner fields completed there rather than sent to us.
Operated by Reality Contact, LLC. Reality Contact, LLC is not a law firm and this is not legal advice. We do not file with DOS; you file. We collect no ID numbers, dates of birth, or home addresses.