IMPORTANT. We have four days left to comment on atf41P. Please comment today!
The ATF cutoff is 4 days away. There are only 4,506 comments that have been received. It is time for everyone who has an NFA Gun Trust to make a comment on this rule.
So far, only 4500 comments have been received.
Make your comments right here:
http://www.regulations.gov/#!documentDetail;D=ATF-2013-0001-0001
Please ask exe very NFA owner and non NFA firearms owners to comment against this rule.
Please forward this information to everyone that you know who owns a firearm. We need additional comments and we need them now!
I will be sending daily emails reminding everyone to make comments on this backdoor attack on our rights and urging everyone on this list to reach out to firearms owner that they know.
This is VERY important. If this rule passes, it will significantly impact your ability to purchase new silencers and short barrel rifles.
Please make the comment at: Comment on ATF41P here
The comments are generally centered around these topics:
LEGITIMATE Purpose: Trusts and other Legal Entities have a legitimate purpose.
ATF's Cost and Benefit Analysis is Flawed
Legitimate Uses of NFA Firearms
ATF uses false assumptions for CLEO refusals. My CLEO will not sign new Forms
Criminals do not use Registered NFA firearms and NFA Firearms are not used for Crimes.
ATF's Proposals will not prevent crime nor stop what they fear from being able to happen.
Here is a suggested comment:
Individual with "Corporations, LLC or Trust"
I am opposed to the Bureau of Alcohol, Tobacco, Firearms and Explosives proposed rule, docket number ATF 41P, on transfers of NFA firearms to "legal entities" such as trusts and corporations. I have created a [TRUST - CORPORATION - LLC - Family Limited Partnership - ETC.] to make, receive and purchase Firearms and items that are regulated by the National Firearms Act. Based on my experience , the BATFE is wrong on MANY issues.
The BATFE is wrong in stating that law enforcement officials only refuse to sign off due to liability fears. That was not my experience. The refusal of CLEO's to sign forms is often politically motivated. In [NAME OF JURISDICTION], the [POLICE CHIEF/SHERIFF] refuses to sign off on these transfers because [EXPLAIN AND PROVIDE EVIDENCE SUCH AS STATEMENTS MADE TO APPLICANTS].
BATFE's estimate of the additional costs imposed by ATF41P are unrealistically low regarding the cost for photographs and fingerprints and fail to include the additional costs in fuel, wear and tear on my vehicles and the value of my time. BATFE's estimates that photographs would cost $8.00 and take an average of 50 minutes to obtain, and that fingerprints would cost $24.00 and take 60 minutes to obtain is also incorrect. In my experience, the costs and times are higher. It cost me [AMOUNT] to get photographs, which took [AMOUNT OF TIME]. And it cost me [AMOUNT] to get fingerprints, which took me [AMOUNT OF TIME]. BATFE considers the cost of providing documents to establish the existence of a "legal entity," based on an estimated average of 15 pages. My own [TRUST - CORPORATION - LLC - Family Limited Partnership - ETC] documents were [NUMBER] pages long.
These costs must be multiplied by the number of "responsible persons" on the application. The BATFE estimates only two responsible persons per legal entity. I believe that is a very low estimate. My own [TRUST - CORPORATION - LLC - Family Limited Partnership - ETC] includes [NUMBER] people who would qualify as "responsible persons" under ATF's definition.
The definition of "responsible person" is another issue of particular importance. The BATFE's wording is different for different types of entities. However, the BATFE's general definition would include anyone who "possesses, directly or indirectly, the power or authority ... to receive, possess, ship, transport, deliver, transfer, or otherwise dispose of a firearm for, or on behalf of" the entity. The laws on trusts and corporations are very complex. In my case, it would be very difficult for me to say accurately which of the parties in my [LEGAL ENTITY] fall under this definition. [EXPLAIN AND PROVIDE EVIDENCE SUCH AS CHILD TRUSTEES]. To get a clear answer on that, I would probably need to speak with a lawyer-another cost that ATF fails to consider.
I unequivocally oppose FINGERPRINTS and PHOTOGRAGHS for Responsible persons and the CLEO signoff requirements for any NFA transfer, and suggest the elimination of the CLEO signoff requirement in its entirety.
The ATF cutoff is 4 days away. There are only 4,506 comments that have been received. It is time for everyone who has an NFA Gun Trust to make a comment on this rule.
So far, only 4500 comments have been received.
Make your comments right here:
http://www.regulations.gov/#!documentDetail;D=ATF-2013-0001-0001
Please ask exe very NFA owner and non NFA firearms owners to comment against this rule.
Please forward this information to everyone that you know who owns a firearm. We need additional comments and we need them now!
I will be sending daily emails reminding everyone to make comments on this backdoor attack on our rights and urging everyone on this list to reach out to firearms owner that they know.
This is VERY important. If this rule passes, it will significantly impact your ability to purchase new silencers and short barrel rifles.
Please make the comment at: Comment on ATF41P here
The comments are generally centered around these topics:
LEGITIMATE Purpose: Trusts and other Legal Entities have a legitimate purpose.
ATF's Cost and Benefit Analysis is Flawed
Legitimate Uses of NFA Firearms
ATF uses false assumptions for CLEO refusals. My CLEO will not sign new Forms
Criminals do not use Registered NFA firearms and NFA Firearms are not used for Crimes.
ATF's Proposals will not prevent crime nor stop what they fear from being able to happen.
Here is a suggested comment:
Individual with "Corporations, LLC or Trust"
I am opposed to the Bureau of Alcohol, Tobacco, Firearms and Explosives proposed rule, docket number ATF 41P, on transfers of NFA firearms to "legal entities" such as trusts and corporations. I have created a [TRUST - CORPORATION - LLC - Family Limited Partnership - ETC.] to make, receive and purchase Firearms and items that are regulated by the National Firearms Act. Based on my experience , the BATFE is wrong on MANY issues.
The BATFE is wrong in stating that law enforcement officials only refuse to sign off due to liability fears. That was not my experience. The refusal of CLEO's to sign forms is often politically motivated. In [NAME OF JURISDICTION], the [POLICE CHIEF/SHERIFF] refuses to sign off on these transfers because [EXPLAIN AND PROVIDE EVIDENCE SUCH AS STATEMENTS MADE TO APPLICANTS].
BATFE's estimate of the additional costs imposed by ATF41P are unrealistically low regarding the cost for photographs and fingerprints and fail to include the additional costs in fuel, wear and tear on my vehicles and the value of my time. BATFE's estimates that photographs would cost $8.00 and take an average of 50 minutes to obtain, and that fingerprints would cost $24.00 and take 60 minutes to obtain is also incorrect. In my experience, the costs and times are higher. It cost me [AMOUNT] to get photographs, which took [AMOUNT OF TIME]. And it cost me [AMOUNT] to get fingerprints, which took me [AMOUNT OF TIME]. BATFE considers the cost of providing documents to establish the existence of a "legal entity," based on an estimated average of 15 pages. My own [TRUST - CORPORATION - LLC - Family Limited Partnership - ETC] documents were [NUMBER] pages long.
These costs must be multiplied by the number of "responsible persons" on the application. The BATFE estimates only two responsible persons per legal entity. I believe that is a very low estimate. My own [TRUST - CORPORATION - LLC - Family Limited Partnership - ETC] includes [NUMBER] people who would qualify as "responsible persons" under ATF's definition.
The definition of "responsible person" is another issue of particular importance. The BATFE's wording is different for different types of entities. However, the BATFE's general definition would include anyone who "possesses, directly or indirectly, the power or authority ... to receive, possess, ship, transport, deliver, transfer, or otherwise dispose of a firearm for, or on behalf of" the entity. The laws on trusts and corporations are very complex. In my case, it would be very difficult for me to say accurately which of the parties in my [LEGAL ENTITY] fall under this definition. [EXPLAIN AND PROVIDE EVIDENCE SUCH AS CHILD TRUSTEES]. To get a clear answer on that, I would probably need to speak with a lawyer-another cost that ATF fails to consider.
I unequivocally oppose FINGERPRINTS and PHOTOGRAGHS for Responsible persons and the CLEO signoff requirements for any NFA transfer, and suggest the elimination of the CLEO signoff requirement in its entirety.
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