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https://federalregister.gov/a/2013-21661

Submit your comments in regards to the proposed ATF rule change requiring Trusts and Other Legal Entities to complete fingerprint cards, photos, and CLEO sign-off. Be professional and articulate how you feel. Every comment helps.
 

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You are now able to view comments the ATF received regarding this issue. On the right hand side with details...all the way at the bottom....says "comments" and the number of comments thus far. You can click on that and read what others have to say. Here's one that was particularly good and hits all of the highlights. I'm not saying copy it, change the name, and submit it as is....but use it as a reference if you care about this issue. Less than 300 comments is abysmal for as many NFA owners as we have in this country.

CMS


The current ATF NFA approval delays already constitute a unreasonable burden of time and cost on commerce. The CLEO signature, photos and cards represent an expensive and antiquated system (to both purchaser and taxpayer), that have been replaced by the FBI NICS check system. To use the antiquated long form system is evidence of a desire to add further to the already laughable transfer timelines of the grossly ineffective ATF managed regulatory system.

The NFA branch has consistently been starved of funding by the ATF, consistently minimally staffed, in ways that make the ATF appear to be either an activist regulatory agency, or a woefully inefficient regulatory agency biased toward limiting the freedoms and maximizing regulatory delay imposed on the law abiding citizenry of the United States of America. This obviously also severely limits the success of the industries they regulate.

The requirement to add fingerprint cards, passport photos, and CLEO signature to the form 4 Trust transfer process constitutes:

1: An unreasonable burden on commerce inside individual states (in the form of adding months of Federal delay in the form of an antiquated long form FBI background check to an already 6-12 month Federal delay to a transaction in state commerce).

2: An additional unreasonable burden on commerce in the form of the cost of fingerprint cards and passport photos for the purchaser and also other people associated with the purchaser of the item. These costs are associated with every purchase and are an obvious unreasonable burden on the purchaser and the industries subject to lost sales.

3: An infringement of a law abiding US Citizen's God Given rights to liberty and pursuit of happiness as defined in the Declaration of Independence.

4: An infringement of a law abiding US citizen's Constitutional second amendment rights in the form of the Federal Government providing the CLEO capability to infringe the second amendment rights of a citizen in the form of an ATF required signature the CLEO is not legally obligated to provide. Even sound suppressors are considered to be "firearms" by the Federal Government, and as such, they are protected by the Second Amendment of the US Constitution that this requirement clearly and intentionally provides the capability to infringe.

Eric Holder might fail to see the multiple gross infringements of the US Justice System here, but they are clear and obvious to a layperson as they would be even more obvious to anyone involved in the practice of law.
 

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Thank you, CMS.

This is the comment I was thinking about submitting. I would like the AKF's input on it.

"Rather than changing or reforming the current NFA item application process, I want the entire system removed as it pertains to sound suppressors and other items. I believe that this will increase public safety.

Sound suppressors increase safety by reducing the risk of hearing loss by shooters and bystanders. In the event that someone is forced to defend their spouse, their children, or their own life with a firearm, sound suppressors reduce the risk of hearing loss for the shooter or their spouse or their children.. If a police officer responds to a call, hearing loss can make it more difficult for the shooter to understand and comply with the officer's instructions.

We all know that rifles are easier to employ with high accuracy than handguns, reducing the risk of stray rounds impacting unintended targets such as innocent bystanders and private property. Unfortunately, their normal length makes them more difficult to operate within confined spaces such as a private residence. If more people had short barreled rifles, there would be a lowered incident rate of impacts on unintended targets.

Aside from the fact that the current NFA application process reduces public safety, it also infringes on the rights of American Citizens to equip themselves with current weapons technology.

The current NFA application process, and especially the newly proposed requirements to add fingerprint cards, passport photos, and CLEO signature to the form 4 Trust transfer process constitutes:

1: An unreasonable burden on commerce inside individual states (in the form of adding months of Federal delay in the form of an antiquated long form FBI background check to an already 6-12 month Federal delay to a transaction in state commerce).

2: An additional unreasonable burden on commerce in the form of the cost of fingerprint cards and passport photos for the purchaser and also other people associated with the purchaser of the item. These costs are associated with every purchase and are an obvious unreasonable burden on the purchaser and the industries subject to lost sales.

3: An infringement of a law abiding US Citizen's God Given rights to liberty and pursuit of happiness as defined in the Declaration of Independence.

4: An infringement of a law abiding US citizen's Constitutional second amendment rights in the form of the Federal Government providing the CLEO capability to infringe the second amendment rights of a citizen in the form of an ATF required signature the CLEO is not legally obligated to provide. Even sound suppressors are considered to be "firearms" by the Federal Government, and as such, they are protected by the Second Amendment of the US Constitution that this requirement clearly and intentionally provides the capability to infringe.

Eric Holder might fail to see the multiple gross infringements of the US Justice System here, but they are clear and obvious to a layperson as they would be even more obvious to anyone involved in the practice of law."
 

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You are now able to view comments the ATF received regarding this issue. On the right hand side with details...all the way at the bottom....says "comments" and the number of comments thus far. You can click on that and read what others have to say. Here's one that was particularly good and hits all of the highlights. I'm not saying copy it, change the name, and submit it as is....but use it as a reference if you care about this issue. Less than 300 comments is abysmal for as many NFA owners as we have in this country.

CMS


The current ATF NFA approval delays already constitute a unreasonable burden of time and cost on commerce. The CLEO signature, photos and cards represent an expensive and antiquated system (to both purchaser and taxpayer), that have been replaced by the FBI NICS check system. To use the antiquated long form system is evidence of a desire to add further to the already laughable transfer timelines of the grossly ineffective ATF managed regulatory system.

The NFA branch has consistently been starved of funding by the ATF, consistently minimally staffed, in ways that make the ATF appear to be either an activist regulatory agency, or a woefully inefficient regulatory agency biased toward limiting the freedoms and maximizing regulatory delay imposed on the law abiding citizenry of the United States of America. This obviously also severely limits the success of the industries they regulate.

The requirement to add fingerprint cards, passport photos, and CLEO signature to the form 4 Trust transfer process constitutes:

1: An unreasonable burden on commerce inside individual states (in the form of adding months of Federal delay in the form of an antiquated long form FBI background check to an already 6-12 month Federal delay to a transaction in state commerce).

2: An additional unreasonable burden on commerce in the form of the cost of fingerprint cards and passport photos for the purchaser and also other people associated with the purchaser of the item. These costs are associated with every purchase and are an obvious unreasonable burden on the purchaser and the industries subject to lost sales.

3: An infringement of a law abiding US Citizen's God Given rights to liberty and pursuit of happiness as defined in the Declaration of Independence.

4: An infringement of a law abiding US citizen's Constitutional second amendment rights in the form of the Federal Government providing the CLEO capability to infringe the second amendment rights of a citizen in the form of an ATF required signature the CLEO is not legally obligated to provide. Even sound suppressors are considered to be "firearms" by the Federal Government, and as such, they are protected by the Second Amendment of the US Constitution that this requirement clearly and intentionally provides the capability to infringe.

Eric Holder might fail to see the multiple gross infringements of the US Justice System here, but they are clear and obvious to a layperson as they would be even more obvious to anyone involved in the practice of law.
Now it has 577 comments, which is a nice increase (almost 2x) but is still significantly lower than what it should be. I'm guessing most people feel that the .gov is just going to ignore them, which is understandable but if nobody speaks up you really can't blame anyone but yourself.
 

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Now it has 577 comments, which is a nice increase (almost 2x) but is still significantly lower than what it should be. I'm guessing most people feel that the .gov is just going to ignore them, which is understandable but if nobody speaks up you really can't blame anyone but yourself.
I wonder why people feel that way?
I just filed my comment, and this what it said:
"Your comment will be viewable on Regulations.gov after the agency has reviewed it, which may be an indefinite amount of time. Use your tracking number to find out the status of your comment."
 

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Discussion Starter #7
Still barely over 1000 replies. Sad for the number of NFA owners complaining about the rule change...
 

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2A apathy. Thats a shame as this should be contested territory.

For what it's worth, I submitted your post almost verbatim.
 

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I think the problem is that most common people don't know what the heck this has to do with....I know before I looked into the NFA game I was completely stumped on all the rules.
It is a game of number....they know they can push a small segment around without much pushback and they will continue to break us down that way until the last flag has fallen.
 
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