Around this time last year, Trooper K granted an interview with this reporter to discuss Kristi Noem, and her exploits in the field of canine population control. Never one to rest on his laurels, Trooper was lulled out of retirement to provide this penetrating interview containing his thoughts on the Corporate Transparency Act. For brevity, certain portions of the interview have been omitted, and some of Trooper’s answers have been condensed by removing his woofs.
Trooper K being interviewed
Interviewer (“I”): Trooper, a real pleasure to sit down with you again.
Trooper K (“TK”): My pleasure.
I: Once again, do I detect the aroma of rabbitcense in the air?
TK: Of course. A dog and his favorite tobacco never part ways.
I: So what is it about this Corporate Transparency Act that has caused you to give another interview?
TK: I have to tell you, never in my five years on this planet have I witnessed such a legislative debacle as this Corporate Transparency Act, or “CTA” (definitely not “CAT”) as we like to call it.
I: Just to clarify, five dog years on the planet is the equivalent of how many human years?
TK: Thirty.
I: What’s the debacle?
TK: The CTA requires that small businesses, like the Massachusetts Society for the Decimation of All Rabbits (“MSDAR”), file some sort of report with the Department of Treasury. At least that is what the CTA required at first. Then according to several courts, the CTA couldn’t require small businesses to file this report. Then, according to other courts, the CTA could require small businesses to file this report. Then other courts disagreed with the courts that disagreed with the first set of courts, so maybe we did have to file reports. Or maybe not. Even the Supreme Court weighed in, but no one paid much attention to them. Now it appears that there may be no penalty if you don’t file, so who cares? It was back and forth, forth and back, like watching a pickleball match.
I: So, what’s the current state of the law?
TK: No idea, no one has any idea because whatever is true today, won’t be true tomorrow. I stopped following the follies several weeks ago.
I: What report does the CTA require businesses to file? Why is it such a big deal?
TK: I don’t really know this stuff. However, here is how my lawyer explained it to me. I believe you are my lawyer. You said that when a business is organized, it has to disclose some information about itself to the state where it is organized. Lots of businesses organize themselves in Delaware, for reasons they probably aren’t aware of, other than the fact that their lawyer tells them to do that. Delaware, like most states, wants to know the name of the business, where it is located, and some other information, but not much. It may not even know what the business does. As long as a business pays its taxes, states don’t want to know much about the business.
I: So, what does the CTA have to do with this?
TK: The one thing that states don’t know that the federal treasury department thought it would like to know is who owns the business. Owners of a business are typically the shareholders of the business. The CTA was requiring all small businesses to file a report called the Beneficial Ownership Interest Report (“BOIR”) in which the business identified its principal owners to the treasury department.
I: And why would the Treasury Department want to know this?
TK: To prevent the covert funding of revolutionary activities by terrorists. Make sense?
I: No.
TK: I don’t get it either. But after 9-11 you could pass any law as long as you described its purpose as combatting terrorism.
I: Ouch! So, what’s the big deal about telling the government who are the major shareholders in a company?
TK: Some people don’t want the government to know this stuff because who knows who is going to get access to the information. What if Elon Musk, the DOGE brothers, or Big Balls wants to sneak a peak? Who is going to say no to them?
TK: And there is another big concern. Because not only do businesses have to identify their major shareholders, for reasons no one can explain, those shareholders then have to prove that they are real people, using real documents with their pictures on them, and containing other personal data, like date of birth, by sending into the Treasury Department a picture of such a document, commonly known as a driver’s license, many of which display a person’s social security number. So now the Treasury Department has a gigantic repository of more-than-likely wealthy individuals with their pictures and driver’s licenses, social security numbers, and other personal data. Can you spell invitation to hack?
I: I get it. You are saying that this repository of personal information being assembled by the Treasury Department is a virtual (literally) Fort Knox of hackable personal data that any terrorist organization that the CTA is trying to frustrate would love to obtain unauthorized access to?
TK: Yup.
I: But certainly, this information must be protected to the nth degree by the sharpest minds in the federal government. Correct?
TK: Maybe, maybe not.
I: What do you mean?
TK: I mean that the Department of Treasury was hacked in December of 2024. Right at the time when most businesses were filing their BOIRs. Think about it. Let’s say you were trying to hack the BOIR data base and had figured out how to do it. When would you do it? You would do it when the database had the most amount of data you could hack. And when would that be? At the deadline when all businesses had to file their BOIR reports. So is it any surprise that the Treasury Department announced in vague terms, that it was hacked in December of 2024? And that we still don’t know exactly what was hacked? I think I know what data the hackers were after. However, one could say the government is not being very transparent describing what was hacked. The government said the hackers, “gained access to an unspecified number of unclassified documents maintained by affected users.” Sure sounds to me like BOIR records.
I: OMG! I see why you are so concerned. Let’s say there was a hack of personal data from the Treasury Department. They would have to compensate the victims, wouldn’t they?
TK: Compensate the victims? With whose money? The Treasury Department’s money? The Treasury Department’s money comes from the victims. There is no compensation. Unless you consider Peter paying Peter to somehow compensate Peter for Peter’s loss.
I: How did this issue wind up in your bowl, so to speak?
TK: Like most canine-centric organizations, the MSDAR takes the statutory reporting obligations imposed on it by human beings very seriously. In fact, we have a standing committee, the Canine Corporate Compliance Committee (the “CCCC”) whose sole purpose is to make sure we obey the law. Members of the CCCC were spending so much time trying to figure out how to comply with the CTA reporting requirements, that they were neglecting their primary societal responsibility, which is to kill all rabbits. They were spending their time watching YouTube channels devoted to exploring the minutiae of irrelevance in the CTA. The rabbit population was spiraling out of control. So I took a heavy paw to the situation, and ordered them to ignore the CTA and get back to doing their regular jobs. Not an easy decision, but one which I think humans would be wise to follow as well.
I: Wow, with stuff like that going on, how do you sleep at night?
TK: Like a dog.
Copyright 2025. Peter Kelman. All rights reserved.