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Today is Your Last Chance to comment on ATF41P!

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  • SC-Texas

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    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.
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    KiloKilo

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    Aug 30, 2013
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    Gee, I hope I haven't waited to long to establish a "trust". I just became aware of the Texas NFA Trust a few days ago. I'm wanting to get a suppressor for my .308. I to will comment on the regulation.gov website. Hope I don't wind up on the "Do not approve" list when I submit the forms......
     

    TXARGUY

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    May 31, 2012
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    Wildcat Thicket, Texas
    Commented. I used copy/paste then customized the crap out of it to better suit my thoughts and situation. Thanks Sean for the reminder.

    I had been kicking around the idea of whether or not to comment but your reminder today was the tipping point I needed.
     

    kozmic

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    Done! I kicked the tires for a few weeks then submitted my comment last week. norm_ThumbUp.gif
     

    Dredge

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    Already commented. BTW...I think their counter is broken on the number of comments submitted.
     

    locke_n_load

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    Apr 9, 2013
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    Houston, TX
    Currently, number of comments:9,230.
    Here is my submission (not copied/pasted from anyone by the way).

    I oppose the recommended changes by BATFE, docket number ATF 41P. BATFE has made several bad assumptions with this change, some which would make acquiring certain weapons and accessories nearly impossible for law abiding citizens. Also, the costs associated with these changes are drastically underestimated.


    1. The average trust size is more than two, I can guarantee you that. My own trust has 4 people on it, with others I know having anywhere from 2-5 members on there trusts. This throws the overall estimate of cost for this change extremely underestimated. Also, the cost/time per person is underestimated as well. When approving a single application for a short barreled rifle or suppressor, with a 2 page application, takes 6-9 months for the government to process, can it really be expected that we could get passport photos and fingerprints done within one hour?


    2. The average trust is also much longer than 15 pages. My own trust, which is about as basic as it can be and contain all the legal statements within to keep me within the law, is 33 pages.


    3. CLEO signoff is definitely not a guarantee for any jurisdiction. Many Sheriffs/Chiefs of Police will simply not sign off on an SBR or Suppressor simply because it takes up their time or they are personally opposed to the idea... All when the responsible person applying is a law abiding citizen with a clean record. There is no reason someone's own political/personal beliefs should interfere with others exercising their rights, granted to every free man and protected by our Constitution.


    4. Why should we even need to "apply" to have a short barreled rifle or suppressor? I'm not discussing machine guns here, since I imagine they are somewhere around maybe 10% of all applications for NFA items. How does having a rifle, with a barrel longer than a pistol but shorter than a "rifle" make it any more deadly? It simply bridges the small gap between the traditional rifle and pistol. The same goes for a "silencer" - they actually do not silence the weapon or make it any more deadly... Just suppress the report as to retain the hearing capability of the operator and to not bother those individuals nearby.


    5. Lastly, I don't understand how the second amendment, which ends with "shall not be infringed", be taken to mean regulated, taxed, and licensed? This is the United States of America, the cornerstone and foundation of Freedom. I am opposed to this act that would attempt to further regulate my right to defense for Myself, my Family, and my Country.


    Carlyle A. Locke
    United States Citizen
     

    TheDan

    deplorable malcontent scofflaw
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    Nov 11, 2008
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    Austin - Rockdale
    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.
    Damn right. I commented months ago. I don't own any NFA yet, but I plan on it in the future.
     
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