Good Morning,
Today is Your Last Chance to comment on ATF41P!
Comments MUST BE SUBMITTED by Dec 09, 2013 11:59 PM EASTERN STANDARD TIME. That is 11:00Pm in Texas!
I have been told that some of my friends, clients and fellow gun owners are not commenting because the comments are public record.
Please comment. Now is the time to stand up and be counted or risk losing more of your rights.
This is a back door defacto gun grab by the Obama administration. Make no mistake about it. IT is time to stand up and be counted!
If the Obama Administration was trying to take your modern Sporting rifles (what the liberal media has named "Assault Rifles") away, every one would be sending emails and commenting! When the Obama Administration tried to take the Saiga Semi automatic shotguns away a couple of years ago, there were over 78,000 comments by the end of the comment period! Why is there only 7,000 today for the defacto ban on silencers?
Every gun owner must stand up and be counted! Get with it citizens! Make your voice heard!
Comment here: Regulations.gov
And the direct link to the comment section: Regulations.gov
Here is a suggested comment:
Individual with "Corporations, LLC or Trust"
I am opposed to the Bureau of Alcohol, Tobacco, Firearms and Explosives proposed rule, docket number ATF 41P, on transfers of NFA firearms to "legal entities" such as trusts and corporations. I have created a [TRUST - CORPORATION - LLC - Family Limited Partnership - ETC.] to make, receive and purchase Firearms and items that are regulated by the National Firearms Act. Based on my experience , the BATFE is wrong on MANY issues.
The BATFE is wrong in stating that law enforcement officials only refuse to sign off due to liability fears. That was not my experience. The refusal of CLEO's to sign forms is often politically motivated. In [NAME OF JURISDICTION], the [POLICE CHIEF/SHERIFF] refuses to sign off on these transfers because [EXPLAIN AND PROVIDE EVIDENCE SUCH AS STATEMENTS MADE TO APPLICANTS].
BATFE's estimate of the additional costs imposed by ATF41P are unrealistically low regarding the cost for photographs and fingerprints and fail to include the additional costs in fuel, wear and tear on my vehicles and the value of my time. BATFE's estimates that photographs would cost $8.00 and take an average of 50 minutes to obtain, and that fingerprints would cost $24.00 and take 60 minutes to obtain is also incorrect. In my experience, the costs and times are higher. It cost me [AMOUNT] to get photographs, which took [AMOUNT OF TIME]. And it cost me [AMOUNT] to get fingerprints, which took me [AMOUNT OF TIME]. BATFE considers the cost of providing documents to establish the existence of a "legal entity," based on an estimated average of 15 pages. My own [TRUST - CORPORATION - LLC - Family Limited Partnership - ETC] documents were [NUMBER] pages long.
These costs must be multiplied by the number of "responsible persons" on the application. The BATFE estimates only two responsible persons per legal entity. I believe that is a very low estimate. My own [TRUST - CORPORATION - LLC - Family Limited Partnership - ETC] includes [NUMBER] people who would qualify as "responsible persons" under ATF's definition.
The definition of "responsible person" is another issue of particular importance. The BATFE's wording is different for different types of entities. However, the BATFE's general definition would include anyone who "possesses, directly or indirectly, the power or authority ... to receive, possess, ship, transport, deliver, transfer, or otherwise dispose of a firearm for, or on behalf of" the entity. The laws on trusts and corporations are very complex. In my case, it would be very difficult for me to say accurately which of the parties in my [LEGAL ENTITY] fall under this definition. [EXPLAIN AND PROVIDE EVIDENCE SUCH AS CHILD TRUSTEES]. To get a clear answer on that, I would probably need to speak with a lawyer-another cost that ATF fails to consider.
I unequivocally oppose FINGERPRINTS and PHOTOGRAGHS for Responsible persons and the CLEO signoff requirements for any NFA transfer, and suggest the elimination of the CLEO signoff requirement in its entirety.
Today is Your Last Chance to comment on ATF41P!
Comments MUST BE SUBMITTED by Dec 09, 2013 11:59 PM EASTERN STANDARD TIME. That is 11:00Pm in Texas!
I have been told that some of my friends, clients and fellow gun owners are not commenting because the comments are public record.
Please comment. Now is the time to stand up and be counted or risk losing more of your rights.
This is a back door defacto gun grab by the Obama administration. Make no mistake about it. IT is time to stand up and be counted!
If the Obama Administration was trying to take your modern Sporting rifles (what the liberal media has named "Assault Rifles") away, every one would be sending emails and commenting! When the Obama Administration tried to take the Saiga Semi automatic shotguns away a couple of years ago, there were over 78,000 comments by the end of the comment period! Why is there only 7,000 today for the defacto ban on silencers?
Every gun owner must stand up and be counted! Get with it citizens! Make your voice heard!
Comment here: Regulations.gov
And the direct link to the comment section: Regulations.gov
Here is a suggested comment:
Individual with "Corporations, LLC or Trust"
I am opposed to the Bureau of Alcohol, Tobacco, Firearms and Explosives proposed rule, docket number ATF 41P, on transfers of NFA firearms to "legal entities" such as trusts and corporations. I have created a [TRUST - CORPORATION - LLC - Family Limited Partnership - ETC.] to make, receive and purchase Firearms and items that are regulated by the National Firearms Act. Based on my experience , the BATFE is wrong on MANY issues.
The BATFE is wrong in stating that law enforcement officials only refuse to sign off due to liability fears. That was not my experience. The refusal of CLEO's to sign forms is often politically motivated. In [NAME OF JURISDICTION], the [POLICE CHIEF/SHERIFF] refuses to sign off on these transfers because [EXPLAIN AND PROVIDE EVIDENCE SUCH AS STATEMENTS MADE TO APPLICANTS].
BATFE's estimate of the additional costs imposed by ATF41P are unrealistically low regarding the cost for photographs and fingerprints and fail to include the additional costs in fuel, wear and tear on my vehicles and the value of my time. BATFE's estimates that photographs would cost $8.00 and take an average of 50 minutes to obtain, and that fingerprints would cost $24.00 and take 60 minutes to obtain is also incorrect. In my experience, the costs and times are higher. It cost me [AMOUNT] to get photographs, which took [AMOUNT OF TIME]. And it cost me [AMOUNT] to get fingerprints, which took me [AMOUNT OF TIME]. BATFE considers the cost of providing documents to establish the existence of a "legal entity," based on an estimated average of 15 pages. My own [TRUST - CORPORATION - LLC - Family Limited Partnership - ETC] documents were [NUMBER] pages long.
These costs must be multiplied by the number of "responsible persons" on the application. The BATFE estimates only two responsible persons per legal entity. I believe that is a very low estimate. My own [TRUST - CORPORATION - LLC - Family Limited Partnership - ETC] includes [NUMBER] people who would qualify as "responsible persons" under ATF's definition.
The definition of "responsible person" is another issue of particular importance. The BATFE's wording is different for different types of entities. However, the BATFE's general definition would include anyone who "possesses, directly or indirectly, the power or authority ... to receive, possess, ship, transport, deliver, transfer, or otherwise dispose of a firearm for, or on behalf of" the entity. The laws on trusts and corporations are very complex. In my case, it would be very difficult for me to say accurately which of the parties in my [LEGAL ENTITY] fall under this definition. [EXPLAIN AND PROVIDE EVIDENCE SUCH AS CHILD TRUSTEES]. To get a clear answer on that, I would probably need to speak with a lawyer-another cost that ATF fails to consider.
I unequivocally oppose FINGERPRINTS and PHOTOGRAGHS for Responsible persons and the CLEO signoff requirements for any NFA transfer, and suggest the elimination of the CLEO signoff requirement in its entirety.
