View Full Version : Last Chance to Comment By Dec 9 - BATF - link to portal
Fight Obama's proposed regulations.
http://www.regulations.gov/#!submitComment;D=ATF-2013-0001-0001
Jumped to 4,500 signatures comments from 4,100 this time yesterday, get it!
Jumped to 4,500 signatures comments from 4,100 this time yesterday, get it!
Just added my comment in opposition. Not hopeful that the ATF decision makers will make the right call. I'm sure pressure from above is massive.
Would be interested in joining a class action lawsuit if the reg is implemented. I know that could lead to an unfavorable ruling on NFA ownership in general but this reg is a defacto ban for many of us anyway.
Eurodriver
12-04-13, 08:42
I know that could lead to an unfavorable ruling on NFA ownership in general but this reg is a defacto ban for many of us anyway.
It sure is!
Done. Thanks for the heads up.
Chromium4500
12-04-13, 10:10
Done. RI has State laws prohibiting the possession of anything that would require ATF approval. I don't plan on living here forever though...
Would be interested in joining a class action lawsuit if the reg is implemented. I know that could lead to an unfavorable ruling on NFA ownership in general but this reg is a defacto ban for many of us anyway.
Same here if it comes down to that. My only other hope is that Texas would become a "Shall Sign" state eventually, none of it makes any sense.
Wow, averaging over 500 per day lately, if only we could have gotten that kind of response when the commenting opened up.
Never too late to comment!
thebarracuda
12-04-13, 22:22
Drop them a note, never make it easy for them.
notorious_ar15
12-07-13, 00:15
I got my comments posted last weekend, and have since helped my dad, uncle, and a couple friends post theirs as well. Hopefully lots more realize the importance & step up!
I got my comments posted last weekend, and have since helped my dad, uncle, and a couple friends post theirs as well. Hopefully lots more realize the importance & step up!
You are awesome! Way to be a man about this issue!
Comments left. Also copied and pasted links to a bunch of other forums. Please post your comments there daily until it closes. I think Obama ordered Holer to make the c=hanges, so they will do it regardless of what anyone says, but if the cry is big enough, maybe more attention will be brought to the issue and it will make it harder to shove these ridiculous rules down our collective throats...
I'm keeping the Faith on this one. I think nothing is over til it's over.
PatrioticDisorder
12-09-13, 07:54
Done!
Don't forget that they filter out copied/pasted remarks so that they only count as one!
Make sure you type out something unique.
Just because they are inefficient doesn't mean they're stupid...
Awesome guys!!! Thank you so much!
Djstorm100
12-09-13, 09:47
I was 8973
ericridebike
12-09-13, 10:00
Added mine last night!
I was 8973
Looks like we may get over 10K... when I look now though it shows 8,124. Not seeing any in support.
Looks like we may get over 10K... when I look now though it shows 8,124. Not seeing any in support.
It updates less frequently when people post more, it's weird but I doubt it'll reflect on the site before midnight tonight.
ETA: But I agree, I want to push to 10,000, praying that happens.
PatrioticDisorder
12-09-13, 10:20
Looks like we may get over 10K... when I look now though it shows 8,124. Not seeing any in support.
There is like 2 or 3 different numbers and only one is close to real time I believe, 10k would be nice, but in reality it should be 100k. How many own NFA weapons or have interest in them? Strength in numbers...
There is like 2 or 3 different numbers and only one is close to real time I believe, 10k would be nice, but in reality it should be 100k. How many own NFA weapons or have interest in them? Strength in numbers...
Well, not many are aware, that being said on the 3rd we had 4,200 comments. Today we're double that and it's the ninth. So keep optimistic, I think we'll hit 10,000 submitted on the site and 3-4 thousand written and mailed.
DreadPirateMoyer
12-09-13, 13:39
My comment:
ATF 41P is an absolute mess of a proposal, with many inherent problems that will do nothing to address crime while simultaneously restricting the rights of American citizens. A tradeoff like that -- where no problem is solved yet American rights are diminished -- is absolutely unacceptable. Listed below are my comments elaborating on these issues, and I hope that whoever reviews this proposal agrees with my concerns:
1. This will not stop crime. In fact, the ATF doesn't even cite a single instance of these items being used in a single crime. Even if these items were used in crime, the ATF fails to cite how such a regulation would prevent such crimes. This proposal addresses absolutely nothing at the expense of our rights.
2. CLEO sign-offs are already an impediment to rights, incredibly outdated, and subjective, and expanding such a system in the year 2013 in light of electronic background checks is regressive and unnecessary. A CLEO sign-off is in no way an accurate reflection of a person's criminal or non-criminal nature, and rather acts as a de-facto permitting process for exercising our rights, especially for people who live in areas where CLEO sign-offs are impossible to get and therefore the CLEO sign-off requirement acts as a de-facto ban. Something as arbitrary and subjective as a CLEO sign-off should not be required to exercise a right (could you imagine having to get your local Sheriff's signature, which he can choose not to give, in order to vote?). Rather, with much more accurate and efficient electronic background checks available (that are performed with every NFA-regulated purchase), the CLEO sign-off should be ELIMINATED, not expanded.
3. Local law enforcement is already overburdened protecting and serving its citizens. Expanding the CLEO sign-off, ID, and fingerprint requirements like in ATF 41P will further distract local law enforcement from catching bad guys, and instead force them to spend their limited, scarce time filling out paperwork. This is not their job. This is an impediment to their job. ATF 41P simply makes it even harder for local law enforcement to protect and serve us.
4. The ATF's projections on wait times and costs for these regulations are severely underestimated. For example, it estimates only an average of 2 people are listed as trustees on most trusts, yet as part of my LLC (a regulatory equivalent for NFA-regulated purchases), I plan on having my entire family of 8 on it. Getting fingerprints and photos for ALL 8 PEOPLE in order to exercise a right is an undue burden on me and my family exercising our rights. It is nothing more than the equivalent of a poll tax, which has already been ruled unconstitutional. We should not have to pay additional money and time and have such large burdens placed upon us in order to exercise such enumerated rights.
5. Wait times for NFA-purchase approvals are already excessive, ranging from 6 to 15 months. Such a long, burdensome process is already an impediment to citizens exercising their rights, and follows the line of thought "justice delayed is justice denied." These wait times should obviously be decreased, but instead, ATF 41P will increase these wait times by placing even more regulatory-enforcement burden on the ATF, which is already overwhelmed with approvals as seen by the 6 to 15 month wait times. This proposal makes life harder for citizens by inevitably increasing already-exorbitant wait times TO EXERCISE A RIGHT, and makes life harder for the ATF itself. It does not make sense.
6. ATF 41P has too many unanswered questions and too many unworkable additions. What if children are a part of a trust? Must they also get fingerprints, a CLEO sign-off, and an ID-worthy photograph taken and sent to the ATF for a background check? What if only one of multiple LLC owners or revocable trust trustees lives in an area where they can't get a CLEO sign-off? Does this then act as a de-facto ban on the LLC or trust purchasing these items? Even worse, what if only one of multiple LLC owners or revocable trust trustees lives in a state where NFA-regulated items are banned? Does this then act as a de-facto ban on the LLC or trust purchasing these items, even if it is established in a different jurisdiction?
Overall, ATF 41P is ill-thought and ill-designed. It won't stop crime. It expands an outdated, arbitrary CLEO-signoff system that often acts as de-facto ban on rights, rather than doing what should be done with the advent of electronic background checks: eliminating the CLEO-signoff requirement. It takes resources away from local law enforcement. It is based on severely underestimated costs and membership projections. It increases the wait time ON A RIGHT and further burdens an already-overburdened ATF. It has many loopholes and questions that aren't addressed or are unworkable.
ATF 41P should be soundly rejected. The only thing the ATF should be doing is figuring out ways to streamline the NFA process, not burden it even more.
My comment:
ATF 41P is an absolute mess of a proposal, with many inherent problems that will do nothing to address crime while simultaneously restricting the rights of American citizens. A tradeoff like that -- where no problem is solved yet American rights are diminished -- is absolutely unacceptable. Listed below are my comments elaborating on these issues, and I hope that whoever reviews this proposal agrees with my concerns:
1. This will not stop crime. In fact, the ATF doesn't even cite a single instance of these items being used in a single crime. Even if these items were used in crime, the ATF fails to cite how such a regulation would prevent such crimes. This proposal addresses absolutely nothing at the expense of our rights.
2. CLEO sign-offs are already an impediment to rights, incredibly outdated, and subjective, and expanding such a system in the year 2013 in light of electronic background checks is regressive and unnecessary. A CLEO sign-off is in no way an accurate reflection of a person's criminal or non-criminal nature, and rather acts as a de-facto permitting process for exercising our rights, especially for people who live in areas where CLEO sign-offs are impossible to get and therefore the CLEO sign-off requirement acts as a de-facto ban. Something as arbitrary and subjective as a CLEO sign-off should not be required to exercise a right (could you imagine having to get your local Sheriff's signature, which he can choose not to give, in order to vote?). Rather, with much more accurate and efficient electronic background checks available (that are performed with every NFA-regulated purchase), the CLEO sign-off should be ELIMINATED, not expanded.
3. Local law enforcement is already overburdened protecting and serving its citizens. Expanding the CLEO sign-off, ID, and fingerprint requirements like in ATF 41P will further distract local law enforcement from catching bad guys, and instead force them to spend their limited, scarce time filling out paperwork. This is not their job. This is an impediment to their job. ATF 41P simply makes it even harder for local law enforcement to protect and serve us.
4. The ATF's projections on wait times and costs for these regulations are severely underestimated. For example, it estimates only an average of 2 people are listed as trustees on most trusts, yet as part of my LLC (a regulatory equivalent for NFA-regulated purchases), I plan on having my entire family of 8 on it. Getting fingerprints and photos for ALL 8 PEOPLE in order to exercise a right is an undue burden on me and my family exercising our rights. It is nothing more than the equivalent of a poll tax, which has already been ruled unconstitutional. We should not have to pay additional money and time and have such large burdens placed upon us in order to exercise such enumerated rights.
5. Wait times for NFA-purchase approvals are already excessive, ranging from 6 to 15 months. Such a long, burdensome process is already an impediment to citizens exercising their rights, and follows the line of thought "justice delayed is justice denied." These wait times should obviously be decreased, but instead, ATF 41P will increase these wait times by placing even more regulatory-enforcement burden on the ATF, which is already overwhelmed with approvals as seen by the 6 to 15 month wait times. This proposal makes life harder for citizens by inevitably increasing already-exorbitant wait times TO EXERCISE A RIGHT, and makes life harder for the ATF itself. It does not make sense.
6. ATF 41P has too many unanswered questions and too many unworkable additions. What if children are a part of a trust? Must they also get fingerprints, a CLEO sign-off, and an ID-worthy photograph taken and sent to the ATF for a background check? What if only one of multiple LLC owners or revocable trust trustees lives in an area where they can't get a CLEO sign-off? Does this then act as a de-facto ban on the LLC or trust purchasing these items? Even worse, what if only one of multiple LLC owners or revocable trust trustees lives in a state where NFA-regulated items are banned? Does this then act as a de-facto ban on the LLC or trust purchasing these items, even if it is established in a different jurisdiction?
Overall, ATF 41P is ill-thought and ill-designed. It won't stop crime. It expands an outdated, arbitrary CLEO-signoff system that often acts as de-facto ban on rights, rather than doing what should be done with the advent of electronic background checks: eliminating the CLEO-signoff requirement. It takes resources away from local law enforcement. It is based on severely underestimated costs and membership projections. It increases the wait time ON A RIGHT and further burdens an already-overburdened ATF. It has many loopholes and questions that aren't addressed or are unworkable.
ATF 41P should be soundly rejected. The only thing the ATF should be doing is figuring out ways to streamline the NFA process, not burden it even more.
Responded with the same argument; glad I did!
Put in my comment last night..
loganp0916
12-09-13, 22:13
Responded with the same argument; glad I did!
I just posted a comment with a very similar argument as well.
I found it interesting that posting my comment could be delayed "an indefinite" length of time...
Any idea on when we will find out the results of this?
It's usually not long. A similar time frame for the comment period. Sometimes less like maybe 30 days. They can then do a revision and re-submit for comments. Or just scrap it. It's really hard to say. You have to realize that we are dealing with people above the law that are adept at skating on the thin edges of the ice and calling it good. So who knows, this whole public comment could just be for show. It's possible the ink is already dry on the law in which case it will happen as fast as possible. I'm not sure they have a time frame. We get time restraints but I think they can hold these sort of things over your head indefinitely. To be honest this sounds like something Obama would sign on Christmas night just as little extra jab.
GunTrustLawyer did hell of job.
http://www.guntrustlawyer.com/41p.html
And... NFATCA.... well, to be honest... I can't even understand what the hell they are trying to get across.
http://www.nfatca.org/pubs/NFATCA_petition1209.pdf --- but that's what they filed.
luckydube56
12-11-13, 13:32
And... NFATCA.... well, to be honest... I can't even understand what the hell they are trying to get across.
http://www.nfatca.org/pubs/NFATCA_petition1209.pdf --- but that's what they filed.
They're just re-asserting what they claim was their original proposal which was get rid of CLEO signoff for everyone as a means of encouraging individual applicants as opposed to the legal entity/trust route. Their reasoning, of course, is that Trusts are a dangerous loophole. The ATF will thank them once again for alerting them a second time to this dangerous loophole, I'm sure. They will reinforce the notion that even owners of class 3 items see the need to close this loophole.
What the NFATCA is engaged in can only be described as insanity. It failed and backfired the first time they tried...yet they try the same exact thing expecting different results.
The truth is their strategy was flawed for giving the ATF a reason to stand on even if it is fictitious. So why did they do it? The answer is simple....the NFATCA and ATF are friendly with each other. John Brown has a reputation of being a lap dog for the ATF. They do not see each other as political and organizational foes.
Was at my local LGS over the weekend. Said to expect to get fingerprints and photos for any trustees beginning around May/June timeframe. Guess I'll get what I can before then.
notorious_ar15
12-23-13, 18:09
Was at my local LGS over the weekend. Said to expect to get fingerprints and photos for any trustees beginning around May/June timeframe. Guess I'll get what I can before then.
Is there any indication that this would apply retroactively to existing trust members?
I would put zero stock in anything about this proposal that comes from a local gun store or 99% of other people. Running a LGS or even being a class 3 dealer doesn't give anyone the inside scoop as to what's going on inside the ATF nor does it make them a fortune teller who can predict the future. Its fear mongering and you may even say they're just trying to get more business. There are dozens of ways things can play out with this and no one will know how its going to end up until we actually get there.
Is there any indication that this would apply retroactively to existing trust members?
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