In a significant blow to former President Donald Trump’s golf course portfolio, a New York judge has ruled that Trump is liable for fraud. The ruling, issued by Judge Arthur Engoron on Tuesday, cancels any certificates filed under New York General Business Law Section 130, which governs the filing of certificates by individuals conducting business under assumed names or as partners. This cancellation extends to not only Trump but also his two adult sons, Donald Jr. and Eric, and others associated with him.
While the cancellation of certification does not remove assets from Trump’s ownership, it prevents those assets from conducting business. This means that if Trump filed sports-related certificates under Section 130, they are now considered cancelled.
The judge’s order also mandates that the parties have 10 days to recommend potential independent receivers to manage the dissolution of limited liability companies (LLCs). Although the dissolution of an LLC does not take away a business or asset from Trump, it does require him to either reorganize or relocate the asset or sell it.
One of Trump’s two New York-based golf courses, Trump National Golf Club Westchester, is currently registered as a New York domestic LLC. The other, TNGC Hudson Valley, located in Hopewell Junction, N.Y., is owned by a Delaware LLC. Therefore, Engoron’s order poses potential challenges for Trump’s golf business going forward.
For instance, 99% of TNGC Hudson Valley is owned by DJT Holdings LLC, which is a named defendant in the attorney general’s civil suit. DJT Holdings LLC also holds the same ownership percentage in Trump’s other golf courses in Jupiter, Fla., Pine Hill, N.J., Colts Neck, N.J., Charlotte, N.C., Washington, D.C., and Scotland. Another defendant in the civil fraud case, Trump Endeavor 12 LLC, is the holding company of Trump National Doral Golf Club in Miami.
It remains unclear to what extent Engoron’s ruling will affect the other golf courses owned by Trump. Financial disclosures filed with the Federal Election Commission indicate that Trump’s golf club in West Palm Beach, Fla., is held by the Donald J. Trump Revocable Trust, his golf course in Ranchos Palos Verdes, Calif., is owned by RPV Development LLC, and his Irish links are owned by TW Venture II LLC and TIGL Ireland Enterprises Limited.
Earlier this month, Trump’s name was removed from a publicly owned golf course in the Bronx as part of an agreement approved by New York City’s Department of Parks & Recreation to transfer the Trump Organization’s lease to Bally’s casino chain.
According to Trump’s most recent financial disclosures, he earned as much as $555 million from his golf course assets between January 2022 and April 2023, accounting for roughly half of his reported $1.2 billion in income during that time period.
Trump now has the option to appeal Engoron’s ruling and seek a stay, which would postpone the order’s implementation until after the appeal process. He can also request clarification from the judge on how he and his businesses must comply with the ruling.