Don't let the "Small Landlord" exemption fool you. Even if your building only has 6 units, your landlord might still be subject to Good Cause Eviction laws if they own more than 10 units total across New York State.

LLCs are not automatically "Small Landlords." To claim the exemption from Good Cause Eviction, the Beneficial Owner (the human behind the LLC) must own no more than 10 units total in New York State.

The "LLC Shell Game" (The Trick)

⚠️ The Myth

"My building is owned by '123 Main St LLC' which only owns 6 units, so Good Cause Eviction doesn't apply—even though the owners of '123 Main St LLC' are also the owners of '124 Main St LLC' and '125 Main St LLC'."

Why It's Wrong: This ignores the Attribution Rule.

Landlords love hiding behind LLCs. They set up a separate company for each building so that on paper, each LLC only owns a handful of units. But the law isn't stupid—it looks past the corporate veil to the actual humans pulling the strings.

The Current Law

📜 RPL § 211(3) — Beneficial Ownership Rule

Real Property Law § 211(3) defines a "Small Landlord" based on Beneficial Ownership and Indirect Interest.

The Rule: If one person owns a 10% or greater stake in 20 different LLCs, they are a beneficial owner of all those units. If the total exceeds 10, none of their buildings are exempt.

This means your landlord can't play the LLC shell game. The law aggregates all units owned by the same beneficial owners across all their corporate entities.

How to Verify Your Landlord's Status

📋 RPL § 231-c — Required Disclosure

Landlords are legally required to provide the "Good Cause Eviction Law Notice" with every lease offer.

The Trap: If a landlord claims the exemption, they must be prepared to disclose the names of all natural persons with an ownership interest.

Here's how to investigate:

  • Request the Form: Ask your landlord for the RPL § 231-c Good Cause Eviction Law Notice. If they refuse to provide it, they may be violating the law.
  • Search ACRIS: NYC's Automated City Register Information System lets you search property ownership records. Look for other buildings owned by the same individuals or entities.
  • Check the LLC: Search the NY Department of State business database to find the members of an LLC.
  • Connect the dots: If you find the same names appearing across multiple LLCs that collectively own more than 10 units, your landlord doesn't qualify for the exemption.

🚨 Take Action: Verify Before You Move

Don't let a landlord hide behind a corporate shell.

  • Demand the Form: Ask your landlord for the RPL § 231-c Good Cause Eviction Law Notice. If they refuse, they may be breaking the law.
  • Call Jay Browne: If you suspect your landlord is hiding other properties, contact me. I can perform a beneficial ownership search to pierce the LLC veil and secure your renewal rights.

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