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I fail to understand why there needs to be a rule-change regarding NFA weapons. Feel free to correct me if I am wrong, but crimes committed with NFA weapons are almost zero. Therefore, the NFA system in place obviously works. It will cost the government money to make the changes; aren't there continuing budget issues? It will also cost employees of the BATFE to divert their work hours to a seeming non-issue at a time when the BATFE is already very busy (unless I am mistaken in that regard). Why waste resources on this?

I oppose these proposed regulation changes (docket ATF 41P) for the following reasons:

1. I do not need to prove my citizenship to vote or to obtain and file a federal tax return. Any standard of identification good enough for voting and tax filing should be good enough for obtaining an NFA item. Voting improperly is as dangerous an activity as any, and if the federal standards already in place for the exercise of my voting rights are sufficient, then they should be sufficient for the NFA process.

2. The Chief Law Enforcement Officer (CLEO) certification goes back to before the existence of the National Instant Criminal Background Check System (NICS). It creates a totally arbitrary system under which the local CLEO can prevent NFA purchases based on his/her own personal political agenda. Political bias should NEVER be the deciding factor in determining who gets to exercise their rights, and who does not. The only rule change which makes sense—both in regulatory terms, law-enforcement terms, and in fiscal terms—is to place NICS in charge of approving NFA purchases.

3. Until BATFE can prove that criminal elements are already using trusts and LLCs to obtain NFA items, requiring fingerprints and photographs of every “responsible person” on an NFA trust, or part of a corporation or LLC carrying NFA items, is an unacceptable invasion of privacy. Federal databases are already notoriously porous. Even national security agencies are unable to prevent malicious hacking from accessing their information. If the personal information contained in the NFA database was ever compromised illegally, or obtained by the local, state, or federal government inappropriately, it could be abused. These rule changes presume guilt and leave it to the applicant to prove innocence. That is fundamentally UNAMERICAN! If a person is criminal suspect, then their information should remain private and it should not be forcibly taken from them during the exercise of a constitutional right.

4. NFA trusts are used to secure the inheritance process, so that a child may inherit the assets of the trust from a deceased parent. They are invaluable tools for estate planning, and their beneficiaries should not have to submit to these violations of their civil liberties simply because they have inherited private property.

5. These proposals will have absolutely no impact on crime. Only TWO murders have been committed with legally obtained and registered NFA items since the National Firearms Act was passed in 1934. This is simply NOT a problem. Criminal do not spend the $300 to $1000 to form an NFA trust, and then pay the ATF $200 for a tax stamp for each NFA transfer, and then submit a Form 1 or Form 4, and then wait 6 to 12 months for approval. Nor do they pay the $10,000 or more for a machine gun, nor the upwards of $2000 for a suppressor. And finally, neither do they complete the transfer with a local SOT Federal Firearms License holder before committing a crime. The already existing regulations provide layers and layers of barriers for law-abiding citizens to navigate, which criminals simply not going to attempt.

These proposals have nothing to do with curbing gun violence and have everything to do with forcing law abiding citizens to navigate a byzantine bureaucracy to obtain NFA items or surrender their right to possess them. There are already numerous laws regulating the transfer and possession of NFA items. We simply do not want or need more. I oppose these proposed regulation changes in their entirety and I ask the Bureau of Alcohol Tobacco Firearms and Explosives to retract this proposal completely and indefinitely.

It is a ridiculous proposal on its face, and it is an insult to liberty, personal security, and above all, the trustworthiness with which you view the american citizenry.

The Annoyed Man wrote:My comment:

I oppose these proposed regulation changes (docket ATF 41P) for the following reasons:

1. I do not need to prove my citizenship to vote or to obtain and file a federal tax return. Any standard of identification good enough for voting and tax filing should be good enough for obtaining an NFA item. Voting improperly is as dangerous an activity as any, and if the federal standards already in place for the exercise of my voting rights are sufficient, then they should be sufficient for the NFA process.

2. The Chief Law Enforcement Officer (CLEO) certification goes back to before the existence of the National Instant Criminal Background Check System (NICS). It creates a totally arbitrary system under which the local CLEO can prevent NFA purchases based on his/her own personal political agenda. Political bias should NEVER be the deciding factor in determining who gets to exercise their rights, and who does not. The only rule change which makes sense—both in regulatory terms, law-enforcement terms, and in fiscal terms—is to place NICS in charge of approving NFA purchases.

3. Until BATFE can prove that criminal elements are already using trusts and LLCs to obtain NFA items, requiring fingerprints and photographs of every “responsible person” on an NFA trust, or part of a corporation or LLC carrying NFA items, is an unacceptable invasion of privacy. Federal databases are already notoriously porous. Even national security agencies are unable to prevent malicious hacking from accessing their information. If the personal information contained in the NFA database was ever compromised illegally, or obtained by the local, state, or federal government inappropriately, it could be abused. These rule changes presume guilt and leave it to the applicant to prove innocence. That is fundamentally UNAMERICAN! If a person is criminal suspect, then their information should remain private and it should not be forcibly taken from them during the exercise of a constitutional right.

4. NFA trusts are used to secure the inheritance process, so that a child may inherit the assets of the trust from a deceased parent. They are invaluable tools for estate planning, and their beneficiaries should not have to submit to these violations of their civil liberties simply because they have inherited private property.

5. These proposals will have absolutely no impact on crime. Only TWO murders have been committed with legally obtained and registered NFA items since the National Firearms Act was passed in 1934. This is simply NOT a problem. Criminal do not spend the $300 to $1000 to form an NFA trust, and then pay the ATF $200 for a tax stamp for each NFA transfer, and then submit a Form 1 or Form 4, and then wait 6 to 12 months for approval. Nor do they pay the $10,000 or more for a machine gun, nor the upwards of $2000 for a suppressor. And finally, neither do they complete the transfer with a local SOT Federal Firearms License holder before committing a crime. The already existing regulations provide layers and layers of barriers for law-abiding citizens to navigate, which criminals simply not going to attempt.

These proposals have nothing to do with curbing gun violence and have everything to do with forcing law abiding citizens to navigate a byzantine bureaucracy to obtain NFA items or surrender their right to possess them. There are already numerous laws regulating the transfer and possession of NFA items. We simply do not want or need more. I oppose these proposed regulation changes in their entirety and I ask the Bureau of Alcohol Tobacco Firearms and Explosives to retract this proposal completely and indefinitely.

It is a ridiculous proposal on its face, and it is an insult to liberty, personal security, and above all, the trustworthiness with which you view the american citizenry.

sjfcontrol wrote:Don't you mean if he's NOT a suspect?

locke_n_load wrote:Implementation delayed at least a year, great job for those who submitted comments!

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