Bulletin: NY000554

Stewart Title Insurance Company has been advised that the New York City Registers Office will no longer accept for recording a Real Property Transfer Tax (RPT) return where any of the parties’ tax payer identification numbers are pending. Previously, a newly formed entity with a pending application to the IRS or an alien entity could list on the RPT all 0’s or 9’s since the number has not yet been issued.  According to the City Registers Office, this practice is no longer acceptable. The only case where the Register will accept a recording without tax identification numbers is on a Referee’s Deed.  Stewart has addressed the issue with the New York State Land Title Association, who in turn is addressing the issue for the industry. 

Please make the appropriate changes in your practices to make sure you have valid tax payer identification numbers on all transfer tax documents to avoid rejection of the document.  Also, for documents that have been rejected for this problem, please make sure you are paying the transfer taxes immediately while you get corrected transfer tax documents, thus avoiding late penalties. The Register will accept the tax payment even though the document has been rejected. 

Should you have any questions or concerns please contact 212-922-0050 and speak with any Agency Legal Counsel.