Today, Attorney Adam Kraut and Chief Counsel Joshua Prince of Firearms Industry Consulting Group® (“FICG®“), a division of Prince Law Offices, P.C., filed a Comment in Opposition to numerous changes that the Bureau of Alcohol, Tobacco, Firearms and Explosives proposed to the 4473 Form.
FICG® raised a plethora of issues, including that ATF is the incorrect federal administrative agency for determinations of prohibition under 18 U.S.C. 922(g), that ATF cannot redefine a “fugitive from justice” in these proceedings, and issues relating to the certification statement. FICG® also requested that ATF revise the 4473 Form, consistent with the ATF Form 1 and Form 4, whereby it would include fields for fictitious entities, instead of requiring FFLs to draft and attach a fictitious entity form as required by 27 C.F.R. 478.124(g), for which, ATF provides no sample form.
Cannabis Industry Law Group (“CILG”), a division of Civil Rights Defense Firm, P.C., also filed a Comment in Opposition raising issue that 27 C.F.R. 478.11 already acknowledges that the use of physician prescribed controlled substances does not result in a prohibition, as well as that ATF is the incorrect federal administrative agency for determinations of prohibition under 18 U.S.C. 922(g). CILG’s stated purpose is to “protect, defend and assert the legal rights of businesses, professionals and individuals to operate lawful cannabis-related businesses and professions and to use cannabis medication without discrimination.”
It will be interesting to see how ATF responds to these and any other comments submitted.