They released a draft letter on their proposed new procedures. Here is a very informative video:

https://www.youtube.com/watch?v=yfDm5yfdh4Q

Actual letter:

https://princelaw.files.wordpress.com/20...ft-12-16-20.pdf

Wow! Who didn’t see this coming? Love it how the ATF states they are trying to provide guidance on what would fall under the NFA or GCA yet, the firearms’ design or features (staring on page 7) can be left for interpretation...”include, but are not limited to” (hint: ATF decides what constitutes a SBR).

Be careful not to make the argument "I want an SBR to not be considered an SBR." I hear this way too often, anyway.

Argue in terms of whether it should be regulated, and not fall into the semantics game of legalese--that's their game and they will always win that way. Even when you get the words you want on a page, they will stretch that whatever way the deem fit. Rather, the argument should be focused on jurisdiction and Article 1 Sec. 1.

Another valid criticism is that this is beyond the parameters of discretionary authority given by Congress for them to resolve independent to Congress. This argument is more compatible with the Republicans on Capital Hill. The former is a principled view, with too many exclusively conservative precepts (few Republicans would hold it).

There was another letter of guidance released in 1791. It was called the Bill of Rights. It supercedes any 3 letter unconstitutional agency

So, if I understand this 'guidance' we're all supposed to register any brace-wearing pistol we have as an SBR and we get to do so for free?

All arguments about what 2A actually means aside, because we lost that one in 1934 and at the polls since, this has both plusses and minuses.

+ Everyone who wanted an SBR and didn't want to go through the time, hassles, and cost just got an expedited process and they got it for free.

- This basically a mass registration of SBRs that were currently unregistered with the Feds.

- This limits what you can do with your 'firearm' going forward once you register it.

Does this mean it's time to fire up those 'gun trusts' and makes sure all family and 'friends' are included?

Of course you can't cross state lines with an SBR unless you file the ATF permission slip. And since crimes aren't committed in any quantity with braced pistols (or "assault rifles" for that matter), this can only be for the purposes of registration.

good points.

If you register as a SBR it will be easy for Northem and company to find it when they declare it illegal/banned.

Take the brace off...

Yeah, but most of the utility goes with it when the brace comes off

Lol..but there’s no paper work and you avoid the registration scheme..

This is massive and could negatively affect literally millions of owners..I see a disaster in the making.

so does the blade on a ar pistol fall into that also

Whatever the unassailable powers that be desire, which is why it’s written so vaguely.

The time to comment has arrived here. Click the "Comment Now!" in the upper right-hand corner of your screen.

Below are some suggested comments from VCDL.

Suggested Comment #1

Policymaking which imposes such a significant burden upon both citizens and industry should not be undertaken lightly. Here, we have burdensome definitional changes / expansions which have the potential to damage or destroy segments of one of America’s few growing industries and it is not based upon an identified problem. Rather, it is based upon mere conjecture.

Suggested Comment #2

The supposed ‘criteria’ laid out in this guidance document are so arbitrary and capricious that no reasonable person could look at them and make an informed decision. The ATF admits as much when they say that evaluations will take place “on a case-by-case basis.” This fails to give adequate notice to those subject to the rules thereby imposed against them. This violates both the procedural and substantive due-process rights of manufacturers, buyers, and those who already own such items.

Suggested Comment #3

Without concrete guidance (comprised of quantifiable design features that place a product in the purview of the NFA), this will only serve to have a chilling effect on the entire marketplace for stabilizing braces. The ATF is empowered to regulate NFA items based upon the clear language of the act, not upon an “I know it when I see it” arbitrary system. It is past time that Congress revisits and refines the deference granted to the administrative aspect of the legislative branch.

Suggested Comment #4

ATF has failed to consider less intrusive forms of regulation that might accomplish the same goals. By specifically defining design characteristics that bring an item under the purview of the NFA, they could achieve the same stated goal without exposing law-abiding citizens to the chilling effect of this arbitrary and capricious definitional scheme.

Suggested Comment #5

Passage of this proposed rule would do nothing to enhance safety but would only place additional bureaucratic roadblocks in front of law-abiding collectors and swamp ATF staff who are already overwhelmed. The result would be a drastic increase in the processing time for NFA applications and potentially a collapse of the stabilizing brace industry.

Great!!! Now we will see what fun is pushed open us after January.

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