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Points to Consider When Commenting on ATF’s Proposed Changes to NFA Transfers

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The American Silencer Association has been very kind to share some points to consider when commenting on the so called 41P, a Notice of Action for Machine Guns, Destructive Devices and Certain Other Firearms; Background Checks for Responsible Persons of a Corporation, Trust or Other Legal Entity With Respect To Making or Transferring a Firearm,

· 41P does nothing to address crime
o NFA items rarely used in crime
· Increased wait times for gun owners
o NFA Branch already understaffed for current load
· In the original abstract, ATF published that they sought to “eliminate the requirement for a certification signed by the CLEO”
o Change in stance is politically motivated, not fact based
· CLEO signoffs:
o Subjective
o Often politically motivated
o Create de facto bans in areas across the country
· Undue burden on Law Enforcement
o Overworked and underfunded
o No compensation for processing forms
· Confusing definition and designation of RPs
o What if a beneficiary is a minor?
o What if a beneficiary lives in a restricted state or jurisdiction?
o What if a beneficiary lives in a legal state, but a jurisdiction where CLEOs refuse to sign?
· Inaccurate time and cost estimates
o Increased burden on individuals purchasing passport photos and fingerprints on trusts – surpassing ATF estimates
o Additionally, ATF estimates $8 and 50 minutes for passport photos and $24 and 60 minutes for fingerprints
· ATF underestimates number of individuals in trusts and legal entities
o They estimate two people per trust

Some additional resources from the American Silencer Association include their stance on 41P: americansilencerassociation.com/american-silencer-association-statement-on-atf-41p. They’ve also prepared a page on recommendations on how to comment against 41P: americansilencerassociation.com/how-to-comment-against-atf-41p.

To make your voice heard:
-Go to www.federalregister.gov/articles/2013/09/09/2013-21661/machine-guns-destructive-devices-and-certain-other-firearms-background-checks-for-responsible.
-Read everything posted about the proposed changes
-Post your comments
-Bottom Line Up Front; Begin your comments with “I am in opposition of the proposed changes” so that, in the odd chance that you agree with some points and oppose others you will not be considered in the “I love the proposed changes” column even though you don’t agree with all of it.

I suggest you use your own voice, keep it civil, direct and to the point, and use proper grammar to be most effective. Do not use a form letter. These are ignored.

7 Responses to “Points to Consider When Commenting on ATF’s Proposed Changes to NFA Transfers”

  1. Matt Carroll says:

    I am in opposition of the proposed changes.

    These rule changes do nothing to address crime. It is already illegal to let unauthorized persons use firearms and NFA items

    Legal NFA items are rarely used in crimes. If a person is willing to submit to background checks and an extended wait time they are showing a good faith effort that they are a law abiding citizen. It is a statistical anomaly to see a legal NFA item used in a criminal act. The facts are that creating a suppressor, short barreled rifle, or a machine gun is not technically difficult. People who have done the NFA paperwork using a trust do so because they are making a legitimate effort to comply with all U.S. laws, not because they are trying to game the system or pass through a loophole.

    Time and Cost:

    The NFA branch already has a backlog of paperwork stretching wait times for stamp approval to a year or more without this extra burden. The NFA examiners seem to be overburdened already from my firearms purchasing experience. I understand wait times have increased up to or past a year long wait. It is amazing that in this world of technology it takes so many months to review paperwork and issue a stamp, especially when a person already owns title 2 firearms. In any efficient or logical system the paperwork burden and wait would decrease for subsequent stamps after a person’s initial NFA purchase and stamp issuance.

    Chief Law Enforcement Officer:

    Signoffs are subjective, sometimes politically motivated, create de facto bans in some areas of the country, and cause undue burden on local law enforcement who are already overworked and underfunded. They get no compensation and have no obligation to take on this proposed new task. In some local political climates it would be career ending for a Sheriff to sign off on NFA paperwork, even though they assume no legal responsibility in signing the NFA forms. For this reason alone I do not expect many CLEOs to take on this new proposed task.

    Thank you,
    Respectfully
    -Matt

  2. xdarrows says:

    Done. Hopefully all of your readers will invest a few moments of their time to visit the Regulations.gov site and make an appropriate comment in support of our besieged Second Amendment rights.

    http://www.regulations.gov/#!documentDetail;D=ATF-2013-0001-0001

  3. Reverend says:

    Completed.

    It would be nice if the gun owners who are gun enthusiasts could organize well enough to replace some of the gunhaters in politics at all levels.

  4. orly? says:

    1. NFA items rarely used in crime

    I can easily think of several scenarios where you can easily take out dozens of unarmed/armed citizens unexpectedly with one suppressed weapon, and I’m considered a “novice.”

    As is is they are MUCH easier to hide than a bomb (and perhaps easier to obtain), all it takes is abit of imagination.

    2. NFA Branch already understaffed for current load

    There’s a reason the ATF is understaffed compared to almost every other Federal agency/some police departments.

    The facts may surprise you.

    • Abrasive says:

      “I can easily think of several scenarios where you can easily take out dozens of unarmed/armed citizens unexpectedly with one suppressed weapon, and I’m considered a “novice.””

      Not sure what your point is here, but this is a silly argument, and is baseless on its face.
      I can easily think of several scenarios where you could take out dozens of unarmed citizens using a large pickup truck, or a hammer, or a large knife. None of which are regulated, nor constitutionally protected.
      Think first, then try to write something coherent.

    • SSD says:

      You are now in the world of pre-crime. Facts are facts. Legally Registered NFA items are not used in crimes. It’s that simple. Could they be? Sure, but so could virtually every other object we possess.

      • orly? says:

        Yes, we have been in a world of “pre-crime.”

        From the moment citizens of the US were put into internment camps simply because of their heritage, a war was declared with extremely faulty intel with the premise of a “pre-emptive strike”, and the word “conspiracy” became a common household word.