Daniel Hardwick, a member of Cozen O’Connor’s Real Estate Practice, discusses the proposed Real Estate LLC Transparency Amendment Act of 2018 in the Washington Business Journal. The proposed legislation would give Washington, D.C., access to the names of all individuals with a financial interest in LLCs created to manage, or own residential properties as a landlord. The bill is part of an effort to help the city discipline landlords who are not meeting D.C. housing codes.

"The bill could be difficult to enforce,” Daniel said. “Developers could work around the policy, for example, by simply naming LLCs as members of an LLC.”

He also noted that members could add new members or sell their membership interest to an LLC after the Department of Consumer and Regulatory Affairs issues a residential business license. "It's going to be difficult to police given the LLC structure," he continued. "An LLC basically allows the membership interest to be traded among individuals all day long. You might have 10 owners one day and later five owners decide they don't want to be involved anymore."

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