Overview
Alysse McLoughlin said the New York City Finance Department’s policy update on sourcing receipts by broker-dealers “raises several interesting issues, as it is not clear whether this is the only situation in which the department will assert that the separate existence of a single member LLC should be recognized.” For instance, she asked if the status of a registered broker-dealer flow down for sourcing purposes to any disregarded SMLLCs owned by the broker-dealer.