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 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.