Significant Comment Filed in Opposition to ATF 41P

The Firearms Industry Consulting Group, a division of Prince Law Offices, P.C.,  is pleased to announce that it was retained by David M. Goldman of and the Apple Law Firm PLLC to prepare a detailed filing in opposition to ATF’s proposed rule 41P.  Mr. Goldman is the founder and owner of Gun Trust Lawyer® and he is recognized as one of the leading lawyers nationally with respect to issues relating to gun trusts and is often quoted by the media in stories addressing such issues.

Because there is a substantial delay in the posting of newly filed comments due to the government shutdown, Mr. Goldman decided to post the filing on his own Website to serve as a model for what other interested persons with different interests (such as small business FFL dealers and custom manufacturers, large silencer manufacturers, law enforcement organizations, and groups concerned with hearing loss) might care to develop and file.

You can find Mr. Goldman’s posting here.

Firearms Industry Consulting Group has been leading the fight against this rulemaking since August and we are prepared to assist other interested persons in making their views known to ATF.

7 thoughts on “Significant Comment Filed in Opposition to ATF 41P

  1. Today, Thursday, October 17, ATF returned to normal staffing levels and for the first time in weeks we can see the first new additions to the “posted” comments. Seventy-two comments were made available on, bringing the total to 1074. Many more comments have been “received” by ATF and await review before they will be released. How far behind is ATF in giving you an up-to-date view of the concerns raised by the public comments? I know of two comments filed in September that still have not been posted.


  2. I submitted a comment on Sept 30 via the site and sent a paper copy to Brenda Friend via First Class mail a few days later. As of yesterday I was unable to locate either on


  3. here is the comment I Posted

    The Second Amendment is an individual right See District of Columbia v Heller 2008. These regulations add further burden to purchasers of legal firearms and the exercise of a FUNDAMENT ENUMERATED RIGHT. The whole NFA scheme is a TAX upon the EXERCISE of a FUNDAMENT ENUMERATED RIGHT. Requiring fingerprinting etc for which any person must submit to, requires a cost, that “cost” really is a tax upon exercise of a fundament right and therefore UNCONSTITUTIONAL. This whole scheme this is as UNCONSTITUTIONAL as a POLL TAX which SCOTUS had determined was UNCONSTITUTIONAL for the same reasons.
    Further the burden of the requirement of a sign off of a CLEO will give similarly situated persons (trusts) different outcomes solely based upon the disposition of the CLEO to sign off on any transfer. This is because there is no requirement for a CLEO to approve any NFA paperwork unless they have cause specifically described in any state’s code, or county ordinance. I know of no such state laws, or county ordinances anywhere that would require a CLEO to approve any transfer for a person who is legally qualified to purchase, and possess a pistol. Because of this the CLEO approval is discretionary. No fundamental right or exercise thereof can be left to the discretion of another! This proposed regulation is on its face UNCONSTITUTIONAL and should not be approved. I would think that some sworn personnel who took an oath to defend the United States Constitution would be able to understand that advancing this proposed regulation is a violation of their oath of office and may constitute treason.


Leave a Reply

Fill in your details below or click an icon to log in: Logo

You are commenting using your account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s