ATF FEEDBACK

[KroyWen]

Comment Period Open on Biden’s Illegal Background Check Rulemaking

Take Action: The official comment period on ATF’s rulemaking, “Definition of ‘Engaged in the Business’ as a Dealer in Firearms," began on Friday, September 8th, 2023.

www.ammoland.com

Read more: NRA-ILA | Your Help Urgently Needed! Comment Period Open on Biden’s Illegal Background Check Rulemaking


Comment Period Open on Biden’s Illegal Background Check Rulemaking
one of these links should work

 

[AKguy1985]

F the ATF. That's all I got to say about them.

 

[Snattlerake]

Absolute power corrupts absolutely.

 

[sumoj275]

Middle finger emoji can’t be posted there

 

[BobbyV]

Here's what I submitted . . . be sure to edit it so it's not exactly the same if you choose to submit comments.

This is a rebuttal against ATF 2022R-17. The ATF lacks the necessary resources and capacity to manage the anticipated increase in Federal Firearms Licensees (FFLs) that could result from the proposed regulation. The ATF is not be adequately prepared to handle the administrative workload that would come with regulating a potentially large number of new FFLs. I question the true intent of the proposed rule, and suggest that it is not primarily be about enhancing public safety but rather exerting pressure on various stakeholders, such as Internet service providers, gun shows, and technology platforms. The concern is that these stakeholders may be compelled to cease involvement in private gun sales due to vague threats of "administrative action" for non-compliance. The proposed regulation will not effectively target the criminal elements, such as cartels, gang members, firearm smugglers, and violent individuals, who may be the primary concern for lawmakers. The proposed rule will disproportionately affect law-abiding individuals while failing to significantly impact criminal activities related to firearms. ATF’s proposal involves a series of presumptions for both who is “engaged in the business” of dealing in firearms and who intends to “predominantly earn a profit” from selling guns. None of these presumptions appear anywhere in federal statute and many of them concern common and entirely innocent conduct. Incredibly, ATF itself even admits that the presumptions would not apply in criminal cases, meaning the rulemaking is irrelevant to the most dangerous elements of society, while it still could be used to intimidate those who are inclined to follow the law. I suggest that the ATF is interpreting and applying the law in a way that goes beyond the statutory language, potentially leading to confusion or unintended consequences. Many of these presumptions concern common and entirely innocent activities related to firearm transactions. This raises concerns that law-abiding individuals engaged in legitimate activities could inadvertently fall afoul of the regulations due to these presumptions. These presumptions have very limited relevance in criminal cases. It is claimed that the presumptions outlined in the rulemaking would not apply in criminal cases. This raises questions about the practical effectiveness of the regulations in addressing the most dangerous elements of society, as they might not deter or impact criminal behavior significantly. Instead, the argument suggests that the regulations could potentially be used to intimidate individuals who are inclined to follow the law. I also argue that the ATF's estimates of the burdens and costs imposed by the rule are based on incomplete or insufficient data, which would lead to an underestimation of the actual costs and burdens on affected parties. I suggest that the regulatory impact analysis conducted by the ATF may not fully account for the potential economic and administrative implications of the proposed rule. Additionally, the administrative burdens that the proposed rule could impose on both regulated entities and the ATF itself such as increased paperwork, reporting requirements, and compliance efforts will very likely be more time-consuming and costly than estimated. The majority of private firearm sales and transfers among law-abiding individuals do not lead to increased crime or public safety risks. The ATF must recognize the importance of respecting Second Amendment rights and the individual's right to bear arms. Private sales and transfers are often exercised by law-abiding citizens as a legitimate use of their constitutional rights. The ATF is very aware of the fact that criminals engaged in illegal activities, such as gun trafficking and prohibited possession, will not comply with the proposed regulations. The ATF is also aware that the regulations primarily affect law-abiding citizens. I would like to remind the ATF of the existing federal and state regulations that already govern firearm transactions, including background checks and restrictions on prohibited persons. Additional regulations are redundant or unnecessarily burdensome for responsible gun owners. Law enforcement efforts should focus on targeting and prosecuting those who engage in criminal activities involving firearms, rather than imposing broader regulations on private transactions among law-abiding citizens.

 

[HillsideDesolate]

Here's what I submitted . . . be sure to edit it so it's not exactly the same if you choose to submit comments.

This is a rebuttal against ATF 2022R-17. The ATF lacks the necessary resources and capacity to manage the anticipated increase in Federal Firearms Licensees (FFLs) that could result from the proposed regulation. The ATF is not be adequately prepared to handle the administrative workload that would come with regulating a potentially large number of new FFLs. I question the true intent of the proposed rule, and suggest that it is not primarily be about enhancing public safety but rather exerting pressure on various stakeholders, such as Internet service providers, gun shows, and technology platforms. The concern is that these stakeholders may be compelled to cease involvement in private gun sales due to vague threats of "administrative action" for non-compliance. The proposed regulation will not effectively target the criminal elements, such as cartels, gang members, firearm smugglers, and violent individuals, who may be the primary concern for lawmakers. The proposed rule will disproportionately affect law-abiding individuals while failing to significantly impact criminal activities related to firearms. ATF’s proposal involves a series of presumptions for both who is “engaged in the business” of dealing in firearms and who intends to “predominantly earn a profit” from selling guns. None of these presumptions appear anywhere in federal statute and many of them concern common and entirely innocent conduct. Incredibly, ATF itself even admits that the presumptions would not apply in criminal cases, meaning the rulemaking is irrelevant to the most dangerous elements of society, while it still could be used to intimidate those who are inclined to follow the law. I suggest that the ATF is interpreting and applying the law in a way that goes beyond the statutory language, potentially leading to confusion or unintended consequences. Many of these presumptions concern common and entirely innocent activities related to firearm transactions. This raises concerns that law-abiding individuals engaged in legitimate activities could inadvertently fall afoul of the regulations due to these presumptions. These presumptions have very limited relevance in criminal cases. It is claimed that the presumptions outlined in the rulemaking would not apply in criminal cases. This raises questions about the practical effectiveness of the regulations in addressing the most dangerous elements of society, as they might not deter or impact criminal behavior significantly. Instead, the argument suggests that the regulations could potentially be used to intimidate individuals who are inclined to follow the law. I also argue that the ATF's estimates of the burdens and costs imposed by the rule are based on incomplete or insufficient data, which would lead to an underestimation of the actual costs and burdens on affected parties. I suggest that the regulatory impact analysis conducted by the ATF may not fully account for the potential economic and administrative implications of the proposed rule. Additionally, the administrative burdens that the proposed rule could impose on both regulated entities and the ATF itself such as increased paperwork, reporting requirements, and compliance efforts will very likely be more time-consuming and costly than estimated. The majority of private firearm sales and transfers among law-abiding individuals do not lead to increased crime or public safety risks. The ATF must recognize the importance of respecting Second Amendment rights and the individual's right to bear arms. Private sales and transfers are often exercised by law-abiding citizens as a legitimate use of their constitutional rights. The ATF is very aware of the fact that criminals engaged in illegal activities, such as gun trafficking and prohibited possession, will not comply with the proposed regulations. The ATF is also aware that the regulations primarily affect law-abiding citizens. I would like to remind the ATF of the existing federal and state regulations that already govern firearm transactions, including background checks and restrictions on prohibited persons. Additional regulations are redundant or unnecessarily burdensome for responsible gun owners. Law enforcement efforts should focus on targeting and prosecuting those who engage in criminal activities involving firearms, rather than imposing broader regulations on private transactions among law-abiding citizens.

Well worded but no-one will read it.

Imma stick to "ATF? More like Gay AF"

 

[BobbyV]

Well wonder but no-one will read it.

Imma stick to "ATF? More like Gay AF"

I'm sure it'll get ignored, but it's at least there now.

 

[harley128]

good job