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An Update on 41P

On January 14th, the Board of the American Silencer Association met with the leadership of the NFA Branch of the ATF. The meeting was cordial and productive, with the focus of the conversation centered on ATF 41P. After SHOT Show, we will post a full debrief of the meeting. For now, we would like to give you a brief update.

In all, there were 9,504 comments received on the Federal Register. Of those, around 1,000 were disqualified for vulgarity, anonymity, or non-applicability. As you know, the overwhelming majority of comments were in opposition to the proposed CLEO signoff requirement. The ASA comment can be viewed here: ASA Comment

The standard timeframe for a final ruling is generally six months after the close of the comment period. However, because of the overwhelming amount of comments submitted, the final ruling will likely take at least a year to be issued. This is because each qualified comment must be responded to by the ATF in writing. With nearly 8,500 qualified comments, this will take quite some time.

After the final ruling is issued, there are generally 60 days before implementation. Until the ruling is released, we will not know if forms that are already in the transfer process will be exempt from the proposed requirements. However, if history is an example, it is likely that all forms received by the ATF prior to the implementation of the final regulation will be exempt.

The ASA is proud to represent this industry, and proud to have your support. Were it not for your comments, the CLEO signoff would have easily passed. Your efforts have made the administration think twice about requiring the antiquated and unnecessary signoff requirements for all transfers. The ASA will continue to work to ensure that it is removed. With your help, we will succeed!

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