Bullet Points for 41P

As the deadline for comments on ATF 41P approaches, the ASA encourages you to take a stand. In order to make your voice heard, submit comments to the Federal Register. All submissions must be made by 11:59 p.m. Eastern Time on Monday, December 9th. To assist you in your comments, we would like to provide talking points for reference:

  • 41P does nothing to address crime
    • 41P cites zero instances where NFA items were used in a crime
  • CLEO signoffs are:
    • Outdated, given computerized background checks
    • Subjective
    • Politically motivated
  • Undue burden on local Law Enforcement
    • Overworked and underfunded departments
    • No compensation for processing forms
  • Inaccurate time and cost estimates
    • Increased burden on individuals purchasing passport photos and fingerprints on trusts – surpassing ATF estimates
      • ATF estimates $8 and 50 minutes for passport photos and $24 and 60 minutes for fingerprints
    • Underestimation of the number of individuals in each trust and legal entity
      • ATF estimates two people per trust
  • Longer wait times for NFA transfers
    • Increase workload for understaffed NFA Branch
    • Current wait times are already inexcusable
    • 41P will exacerbate the problem
  • Too many unanswered questions
    • What if a beneficiary is a child?
    • What if a secondary beneficiary or trustee lives in a restricted state or jurisdiction?
    • What if a secondary beneficiary or trustee lives in a legal state, but a jurisdiction where CLEOs refuse to sign?

The ASA encourages all individuals to submit comments to BATFE on the proposed rule change. If you would prefer to submit a customizable form letter, please see our previous post: How to Comment Against ATF 41P.

To submit, there are several available methods. You may submit comments, identified by docket number (ATF 41P), by any of the following methods:

  1. Federal eRulemaking Portal 
  2. Fax: (202) 648-9741
  3. Mail: Brenda Raffath Friend, Mailstop 6N-602, Office of Regulatory Affairs, Enforcement Programs and Services, Bureau of Alcohol, Tobacco, Firearms, and Explosives, U.S. Department of Justice, 99 New York Avenue NE., Washington, DC 20226; ATTN: ATF 41P.
All submissions must include the agency name, Bureau of Alcohol, Tobacco, Firearms and Explosives, and the docket number for this rulemaking, ATF 41P. All comments received will be posted without change to the Federal eRulemaking portal, including any personal information provided. For additional information about the comment and rulemaking process, click here.
Again, the comment period ends at 11:59 p.m. Eastern Time on Monday, December 9th. Be sure to make your voice heard!