Comment on ATF Rule by Dec 7
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cody.cl...@gmail.com
Dec 6, 2023, 10:56:43 PM12/6/23
to Thurmont IDPA
Please take time before midnight Dec 7 to comment on the proposed rule from the ATF (
88 FR 61993 ) that would prevent us from selling a firearm withou having a FFL.
Here is a recommended letter:
Dear Attorney General Garland,
I am writing to express my opposition to the ATF's proposed rule "Definition of Engaged in the Business as a Dealer in Firearms." This rule is too broad and will ensnare law-abiding citizens who occasionally sell firearms from their personal collections. The rule is also vague and will create uncertainty for gun owners, making it difficult for them to know whether or not they are in compliance with the law.
Also note that private firearm sales and transfers happen every day among law-abiding people in the real world and do not pose an unreasonable public safety risk that gun prohibition advocates claim. Criminals will not be concerned about ATF rules and the rule only serves to further penalize and burden law abiding citizens.
Specifically, I am concerned about the following:
The rule defines a dealer as someone who "devotes time, attention, and labor to dealing in firearms as a regular course of trade or business to predominantly earn a profit through the repetitive purchase and resale of firearms." This definition is too broad and could capture people who occasionally sell firearms from their personal collections, such as someone who sells a few guns each year to fund their hobby.
Conservative estimates are that this rule would create another 25,000 to 300,000 FFLs. I have concerns at the ATF's ability to handle the increased workload.
In addition to workload, the true financial cost to the taxpayers for this rule are unknown. I am concerned about the accuracy of ATF's estimate and that the true cost of the rule will likely be much higher, adding untold millions in taxpayer burden.
The rule also includes a presumption that a person is engaged in the business of dealing in firearms if they sell five or more firearms in a calendar year. This presumption is unfair and could lead to people being prosecuted for unknowingly violating the law.
Finally, the rule does not include a definition of the term "personal collection." This lack of a definition could make it difficult for gun owners to know whether or not they are in compliance with the law.
In addition to these specific concerns, I also argue that the rule is an overreach of the ATF's authority and that it violates the Second Amendment right to keep and bear arms.
I urge you to withdraw the proposed rule and to work with Congress to craft a more narrowly tailored law that targets criminals and straw purchasers while protecting the rights of law-abiding gun owners.
Sincerely,
I am writing to express my opposition to the ATF's proposed rule "Definition of Engaged in the Business as a Dealer in Firearms." This rule is too broad and will ensnare law-abiding citizens who occasionally sell firearms from their personal collections. The rule is also vague and will create uncertainty for gun owners, making it difficult for them to know whether or not they are in compliance with the law.
Also note that private firearm sales and transfers happen every day among law-abiding people in the real world and do not pose an unreasonable public safety risk that gun prohibition advocates claim. Criminals will not be concerned about ATF rules and the rule only serves to further penalize and burden law abiding citizens.
Specifically, I am concerned about the following:
The rule defines a dealer as someone who "devotes time, attention, and labor to dealing in firearms as a regular course of trade or business to predominantly earn a profit through the repetitive purchase and resale of firearms." This definition is too broad and could capture people who occasionally sell firearms from their personal collections, such as someone who sells a few guns each year to fund their hobby.
Conservative estimates are that this rule would create another 25,000 to 300,000 FFLs. I have concerns at the ATF's ability to handle the increased workload.
In addition to workload, the true financial cost to the taxpayers for this rule are unknown. I am concerned about the accuracy of ATF's estimate and that the true cost of the rule will likely be much higher, adding untold millions in taxpayer burden.
The rule also includes a presumption that a person is engaged in the business of dealing in firearms if they sell five or more firearms in a calendar year. This presumption is unfair and could lead to people being prosecuted for unknowingly violating the law.
Finally, the rule does not include a definition of the term "personal collection." This lack of a definition could make it difficult for gun owners to know whether or not they are in compliance with the law.
In addition to these specific concerns, I also argue that the rule is an overreach of the ATF's authority and that it violates the Second Amendment right to keep and bear arms.
I urge you to withdraw the proposed rule and to work with Congress to craft a more narrowly tailored law that targets criminals and straw purchasers while protecting the rights of law-abiding gun owners.
Sincerely,
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