NFOA MEMBERS FORUM
General Categories => The NFA Corner => Topic started by: RobertH on September 07, 2013, 06:29:01 AM
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you have 90 days. Closes Dec 9, 2013. remember your comments WILL be published online for all to see/read.
https://www.federalregister.gov/articles/2013/09/09/2013-21661/machine-guns-destructive-devices-and-certain-other-firearms-background-checks-for-responsible#addresses (https://www.federalregister.gov/articles/2013/09/09/2013-21661/machine-guns-destructive-devices-and-certain-other-firearms-background-checks-for-responsible#addresses)
what will you say? how will you defend your position? (i'm working on my comments)
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Would a simple "FBHO" suffice?
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bumping this up.... the due date is coming fast! get your comments in after the holiday, since you never know when their servers will be down. im sending mine in next week. i encourage all of us to send comments to the ATF. i am also sending some comments to my federal representatives.
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Left mine the other day.
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Thanks for the reminder. I left a short comment, just now.
I think the turnout on this topic has been less than stellar. There hasn't exactly been a "flood" of comments in opposition to the proposed rule changes (just over 3,000 total; for and against).
If you haven't left a comment, please go here: http://www.regulations.gov/#!documentDetail;D=ATF-2013-0001-0001 (http://www.regulations.gov/#!documentDetail;D=ATF-2013-0001-0001)
Click on the "Comment Now" button at the top-right of the page.
You can see some of the many reasons these rule changes are going to be bad for us here:
http://www.guntrustlawyer.com/2013/09/comments-for-atf-41p-starting.html (http://www.guntrustlawyer.com/2013/09/comments-for-atf-41p-starting.html)
It looks like those of us in Lancaster County (specifically Lincoln) may be totally excluded from purchasing / owning class 3 items (see this thread):
http://nebraskafirearms.org/forum/index.php/topic,10498.0.html (http://nebraskafirearms.org/forum/index.php/topic,10498.0.html)
if the proposed rules go through.
I know not everyone is "into" class 3 items (suppressors, SBRs, etc), but whether you notice it or not, this is a right that is being taken away from you. Don't take action too late; make a comment today, please!
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time is running out! send your comments in now!
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I havent put mine in yet. I have alot i want to say but just javent had time to put it all down. I javr to work next this coming saturday and sunday keeping tabs on a project. Should have plenty of time then
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Dang it just started getting everything together to get an SBR going and now this. And to think I was just in a certain gun store/range and the worker claims all this gun crap going on has nothing to do with Obama....
Hmm.
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if you get your paperwork in before Dec 9, you will get it approved in 3 months (barring any stupid ATF crap). Scott @ American Reaper said all of this eForm 4's are coming in at exactly 3 months.... which means, i might have a very quiet Christmas.
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Re: eForms wait times, check out the cluster of red points in the NFA Tracker trend graph: http://nfatracker.com/TrendGraph.aspx (http://nfatracker.com/TrendGraph.aspx)
Whether these are representative, or just an aberration due to staff training on the new eForms system, remains to be seen.
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I spoke to a gentleman at the NFA branch last week. He informed me that eFiled forms are expected to be approved and mailed within 4 months.
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well, i just filed my comments to the ATF. i also sent a note to our federal reps urging them to stop ATF 41P since its basically small scale gun control measure.
have you (meaning everyone here) sent in your comments? don't stand by and let them win.
what about the NFOA as an organization?
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I was bumping around on ar15 during lunch today and came across a thread with a form letter in it. I has a lot of great information in and is very well written.
If you do not have time to write your own comments please take the couple of minutes to copy and past it fill in your info and submit it. It is just under 5000 words so it can be submitted online
Link
The OP on ar15 stated that the author gave permission for anyone to use it. (http://www.mediafire.com/view/a1a4hk2g3w3vl0e/ATF-41P-Sample-Comment.docx [/url)
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I was bumping around on ar15 during lunch today and came across a thread with a form letter in it. I has a lot of great information in and is very well written.
If you do not have time to write your own commits please take the couple of minutes to copy and past it fill in your info and submit it. It is just under 5000 words so it can be submitted online
http://www.mediafire.com/view/1lmovb4n3b87gdb/ATF-41P.docx (http://www.mediafire.com/view/1lmovb4n3b87gdb/ATF-41P.docx)
The OP on ar15 stated that the author gave permission for anyone to use it.
The American Silencer Association has also provided useful templates for commenting on 41P. I link to ASA's post here: http://silencernews.com/only-five-days-left-to-comment-on-atf-41p/ (http://silencernews.com/only-five-days-left-to-comment-on-atf-41p/)
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well, i just filed my comments to the ATF. i also sent a note to our federal reps urging them to stop ATF 41P since its basically small scale gun control measure.
have you (meaning everyone here) sent in your comments? don't stand by and let them win.
what about the NFOA as an organization?
The question was sent on- A couple of Directors 'in the know' are drafting a response.
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do not just send in a form letter. it will be treated at 1 comment. write your own comment, but you can base it on what those others have written. oh and please no plagiarism.
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http://www.ar15.com/forums/t_6_17/412433_ATF_41P__Some_new__different_comments_against_the_CLEO_sign_off_proposal.html&page=1&anc=bottom (http://www.ar15.com/forums/t_6_17/412433_ATF_41P__Some_new__different_comments_against_the_CLEO_sign_off_proposal.html&page=1&anc=bottom)
This is the thread i got the link from. Sorry if the link is not hot. Im on my phone tonight. The Op says that the offer will let anyone use all of part of the letter. I asked the question about if everyone just submits a form letter would we just get a single form letter back. He agreed that one reply would be made but he also said submitting the same or ver similar letters would show the ATF that we have strongarguments against them.
I am going to do some modify on this to make it my own. But i have friends and family to show there support even though they are not NFA owners. And have no real opions the subject. To me 5 people support a single a well written comment is better then 5 people submitting im against 41p with no facts
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Kind of late for a bump tonight but tomorrow is the last day! I just submitted my commit. Get your commit in before the rush tomorrow!
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Last change everyone! Speak now or forever hold your peace.... well most of us will anyway... ;D
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roughly 9 hours left!
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Sent to:
http://www.regulations.gov/# (http://www.regulations.gov/#)!submitComment;D=ATF-2013-0001-0001
Dear BATFE:
As a loyal American, I would urge the BATFE to NOT adopt stronger laws or rule changes to take away or limit the lawful ability to obtain and own class 3 firearms.
Please let the current laws stand as they are.
Sincerely,
Gary Mayo
1jx-8979-p77i
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http://www.regulations.gov/# (http://www.regulations.gov/#)!submitComment;D=ATF-2013-0001-0001
This string needs to be copied and pasted into an internet address bar in full. As a link, it does not work, because half of it does not highlight.
A working link is at the bottom of this page under COMMENTS
http://silencernews.com/only-five-days-left-to-comment-on-atf-41p/ (http://silencernews.com/only-five-days-left-to-comment-on-atf-41p/)
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Just took a quick look at the comments and virtually all of them oppose the change.
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We're so screwed. How on Earth have only 9K people responded to this?
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Comment sent. Here is a small snippet:
To Whom It May Concern:
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People who are attempting to register an NFA items are by definition law abiding. The Trust "loophole" does not allow barred individuals from obtaining a firearm, as that person is already in possession of a firearm to register. While this may be an issue, this issue has nothing to do with the current NFA process WHATSOEVER.
IF these rules were put into a place then it must be the case that the CLEO signature are "SHALL SIGN/ISSUE" instead of "MAY SIGN/ISSUE" to allow a fair and equally applicable law across the US. Otherwise this will lead to more legal action from entities against these rules at the cost of US tax dollars in order to litigate.
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I do want to iterate the people who register NFA items are attempting to be law abiding citizens who pay the correct taxes. It makes no sense to make it harder on us to that. I want to be a law abiding citizen and I would like to be able to do so without undue hardship. It is up to me as a law abiding citizen to ensure my NFA item is legal in my providence, as it is with any non NFA item I own. We have been trusted for years with this and there have been nearly zero problems with the current system. These changes are not justified.
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We're so screwed. How on Earth have only 9K people responded to this?
Yeah maybe we are its hard to say. They have alot of have alot explaning to do to some of the lawfirms that submited factual commits. By them submitting facts and legal refernces the aft should give a better answer then sorry for you and if they dont answer at all it opens stuff up for lawsuits. The way i understnad the best thing for us legally is they dont reply to anything. They just change the regs and as a group we take them court.
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I asked them to provide a scenario where this rule change will actually keep someone, criminal or not, from committing a crime. Seeing how that is the least of their concerns I am sure it is falling on deaf ears.
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We're so screwed. How on Earth have only 9K people responded to this?
Regulations.gov does not allow comments to be immediately posted. They hold and review, so who is to say the backlog of comments waiting to be approved for posting?
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Yeah maybe we are its hard to say. They have alot of have alot explaning to do to some of the lawfirms that submited factual commits. By them submitting facts and legal refernces the aft should give a better answer then sorry for you and if they dont answer at all it opens stuff up for lawsuits. The way i understnad the best thing for us legally is they dont reply to anything. They just change the regs and as a group we take them court.
This is how I understand it as well. If they just enact the new regulations without responding to the comments and justifying their position then we will have legal standing to go to court and get it overturned.
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and the NFOA response was????
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i've been hearing the ATF will make an announcement around June 2014. stay tuned....
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Wow I am kind of surprised. I thought they would push harder but they are the government after all.
The other thing that sucks is I hate waiting!
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I'm cautiously optimistic that the ATF will either remove the CLEO signoff and keep the background check, or they'll try to push it through and it will be defeated in court. I'm no lawyer, obviously, but I've read some really good comments from lawyers pointing out how this is on shaky legal ground.
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From what I have been told on other sites if the AFT proceeds they will be hit with several largely funded lawsuits. They say they will take them though the supreme court if necessary. I really don't want to see it go that far because I don't think it needs that much public attention but if that is what it takes so be it.
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yes, arfcom has had some really good posts.
still waiting on the NFOA comment......
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I dont know but once again Mr Obama has caused me problems. FINALLY, I decide to get an SBR after 3 years of thinking about it and he does this to me, again....
Once again he causes a "rush" because he wants to limit something, and once again causes way more people to own the very thing he wants to limit, than if he had just left it alone.
What an idiot.
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there are rumors of +70,000 apps in the system now. but that includes eForms 1, 3, 4, etc.
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EFile your app. NFA Branch is saying 4 months to approval for those. (As of two weeks ago anyway)
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EFile your app. NFA Branch is saying 4 months to approval for those. (As of two weeks ago anyway)
Ha well less then two weeks ago it was 90days. If you want to do a e-form people better get inline before it is backed up to a year!
To bad I don't have the coin to put in for mine :(
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EFile your app. NFA Branch is saying 4 months to approval for those. (As of two weeks ago anyway)
Did you get yours filed?
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I filed one yesterday and am going to drop another tonight. Took about 10 minutes! First one is for a 9" 300AAC SBR.
For the second, maybe just a 10.5" 5.56 SBR.
One of these days, I'd like to get a Thompson and SBR it.
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still waiting on the NFOA comment......
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In response to those who have inquired: Some of the board asked me to get a comment together on behalf of NFOA on ATF 41P. I can give lots of excuses (was working on drafting trusts for folks trying to get in under the wire, publishing pieces on silencernews.com and elsewhere encouraging others to comment and helping them figure out what to say, coordinating with Joshua Prince/FICG to try to find a professional economist to help with one aspect of their comment drafting, etc.), but the bottom line is that I didn't get it done.
That is on me. Sorry guys.
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well needless to say im let down. how could this be? we had 90 days. i'm not blaming any one person but how could we, as a group, not send in anything? i know several individual members sent in responses, which is great, but how could the NFOA not? did we have to research it like Josh Prince or Silencer Shop or the NRA? no. but we didn't ask our members for help either. just another example of how the board needs to have better communication with the members. i or a number of others would have helped in any way possible, all we needed was to be asked. what is done is done. now to wait for June 2014 for the response....