By Connor Watt and Pavneet Grewal

In July, the Ministry of Finance began distributing “compliance letters” to land owners in British Columbia who, based on their internal records, may have missed the deadline to file a Transparency Report in accordance with the Land Owner Transparency Act (“LOTA”) by November 30, 2022.

Land owners who received a compliance letter must determine whether they need to file a Transparency Report or whether they are excluded from this requirement. As discussed in our previous article, trusts, corporations or partnerships that have a registered or beneficial interest in land must file a Transparency Report disclosing individual “interest holders” (with some exceptions). Once a determination has been made, letter recipients must either complete and file a Transparency Report, or email the Land Owner Transparency Registry (“LOTR”) to provide an explanation of the basis upon which they are excluded from the obligation to do so.

This should also serve as a reminder to any land owner which owns land via a trust, corporation or partnership, of their obligation to file (and keep current) a Transparency Report in respect of such property. Failure to do so may result in significant administrative or punitive penalties.

If you have questions about whether you are subject to LOTA or you need assistance with filing a Transparency Report, please contact our Commercial Real Estate Group.