proposed C&R FFL rule changes

[somd_mustangs]

I guess we'll know soon enough....

 

[MikeTF]

I'm going to bite my tongue about other changes that they may 'propose'.

 

[somd_mustangs]

This stinks. More hoops to jump through. Thanks Obama. This should go through congress, not through an executive order.

It's not an executive order, the ATF is using the correct process to make "data collection" changes via the "system." No Congress needed here, and by golly the public is free to comment on it so not like they're trying to pull a fast one

whether this is politically directed or not is another issue.

<this set of changes in the Federal Register may have to be approved by Congress, I don't know about that part. There's a LOT of other non-FFL, non-ATF changes here beyond the two pages we see.>

 

[CasualObserver]

Hey. What's more important, this or work.

Well, they are sorta codependent.... apparently this has led to an expensive habit that requires extensive funding, thus the requirement to work.

 

[AssMan]

Well, on the bright side, I'll buy way more firearms in state. I think I've only bought one C&R eligible handgun in MD. Why pay tax, fees, and wait? OTOH, some dealers won't accept a C&R (Loudon Guns). Maybe this will change that. The Feds already have my prints, so while I agree it's BS, that ship has sailed for me. May as well just go for an 01FFL and set-up an online shop.

 

[Mooseman]

Well, they are sorta codependent.... apparently this has led to an expensive habit that requires extensive funding, thus the requirement to work.

Okay. That I understand.

 

[Maxsplat]

Well, on the bright side, I'll buy way more firearms in state. I think I've only bought one C&R eligible handgun in MD. Why pay tax, fees, and wait? OTOH, some dealers won't accept a C&R (Loudon Guns). Maybe this will change that. The Feds already have my prints, so while I agree it's BS, that ship has sailed for me. May as well just go for an 01FFL and set-up an online shop.

I've been thinking of going this route but most of what I hear (taken for what it's worth mind you) is that online sales only FFLs won't happen anymore plus would the State approve it as well?

 

[JHE1956]

It will be interesting to see if we get a disparity among CLEOS in the state in approving C&R applications -- some approving them routinely and some never approving them?

 

[dgapilot]

So, for all that are complaining, this is how the Executive Department works, changes are posted to the Federal Register for PUBLIC COMMENT. If you don't like what's posted, send in comments! The Administrative Procedures Act requires the agency to review and dispose of all comments prior to any change. When you comment, be specific and restrict your comments to the subject at hand. Comments to Notices in the Federal Register are actually more important than voting, they have to review it. Make it a habit to review the Federal Register every day for those agencies you have an interest in. It's surprising what you might learn, and how you can help shape the regulations imposed on you.

 

[dgapilot]

One other point, once you verify what changes they are proposing on the forms, look and see if the data they want to collect is allowed/required by the existing regulations. The form change may require additional info that would then require a regulation change with an entirely new Notice of Proposed Rule Making.
The two notices are only for Form changes as required by OPM. If the new form will cost more $ to the public, or if it doesn't fit the current regulation, it should not be implemented.

 

[Furious George]

And one last point - before you submit a comment, read the actual form for yourself. Don't rely on what someone else has posted about it or told you it says. Read it yourself.

So far, no one has done that.

All of the posting so far is based on a 2nd hand account from someone who may or may not have actually read the proposed new forms.

 

[A1Uni]

Well, on the bright side, I'll buy way more firearms in state. I think I've only bought one C&R eligible handgun in MD. Why pay tax, fees, and wait? OTOH, some dealers won't accept a C&R (Loudon Guns). Maybe this will change that. The Feds already have my prints, so while I agree it's BS, that ship has sailed for me. May as well just go for an 01FFL and set-up an online shop.

One of the big reasons many dealers have issues with 03 licenses is that you can't verify them through FFL Easy Check.

 

[somd_mustangs]

One of the big reasons many dealers have issues with 03 licenses is that you can't verify them through FFL Easy Check.

True enough. Plus the frustration of different rules in different states....

On the other hand, that's exposed to the public so FFL-03's without the infrastructure (alarms, employees, a company to "protect" against liability, etc) are put in a precarious position if now all of a sudden the info is public. I'd rather not have my info spread all over the place.

 

[AC MkIII]

Where is the NRA and what are they doing about this?

 

[Docster]

And one last point - before you submit a comment, read the actual form for yourself. Don't rely on what someone else has posted about it or told you it says. Read it yourself.

So far, no one has done that.

All of the posting so far is based on a 2nd hand account from someone who may or may not have actually read the proposed new forms.

No surprise there.....

 

[Alphabrew]

Well, on the bright side, I'll buy way more firearms in state. I think I've only bought one C&R eligible handgun in MD. Why pay tax, fees, and wait? OTOH, some dealers won't accept a C&R (Loudon Guns). Maybe this will change that. The Feds already have my prints, so while I agree it's BS, that ship has sailed for me. May as well just go for an 01FFL and set-up an online shop.

Agreed (except I have no interest in an FFL01).

 

[ShafTed]

I haven't looked at the proposed changes (yet, but I will, and compose a comment accordingly) but has anyone else recently gotten a renewal notice? Mine came in the mail today and it does look like they are conflating the forms for 03 and other FFLs. One thing I noticed is that if I want to add another "responsible person" (this looks like it's meant for other type licenses) that person has to submit photo & fingerprints but no mention of either for me as the renewer. Also said that if not renewing to send "business" records to ATF, again seems aimed at non-03s but using a multi-purpose renewal form.

 

[Machodoc]

So, for all that are complaining, this is how the Executive Department works ...

Yeah ... the same as the FAA, but they are more sensitive to public feedback than the BATFE is.

Do you have a Howard??!

 

[Machodoc]

Also said that if not renewing to send "business" records to ATF, again seems aimed at non-03s but using a multi-purpose renewal form.

Are you saying that now, if you don't renew, you need to send your Bound Book to them?

 

[Maxsplat]

After reading throught he forms and change requests it LOOKS like C&R would now be subject to the same things as an FFL01. Meaning finger prints, pics, cleo signoff, etc. But, maybe its just me, I'm having toruble identifing if any other changes tot he fourms would be required. Meaning the FFL03 is allowed for personal collections (item 19) where the 01 is not intended for that. So that said if the form was to consolidate the 03 with this form (thanks CasualObserver):

This being the form it appears they would be modifying to add in FFL03 too..
http://www.atf.gov/files/forms/download/atf-f-5310-12.pdf
Note the OMB No. 1140-0018 in the corner of the form which is referenced in the original AR15 post.

Maybe another addition should exclude the 03 from finger prints and the other things that 01s need to do. Almost like a little check box or something that says "Are you a collector (FFL03) yes/no (if no ignore sections X, Y and Z)" Does that make sense?

It's one thing to combine the forms to save trees. It's awhole nother ball game when they change the regs to may the 03 as difficult to get as an 01. I do believe that the process of combining the forms would make it more confusing for us and you woul dsee a drop in FFL03s. Face it we all hate paperwork and Gov't paperwork gets more confusing by the hour.

Maybe someone else can read through and get some more information out of it that I'm missing or totally messing up.