In a 16 page draft copy of proposed rulemaking/guidance specifying “Objective Factors for Classifying Stablizing Braces”, the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) has proposed entering into rulemaking to delineate the objective factors considered when “evaluating firearms with an attached stabilizing brace to determine whether they are considered firearms under the National Firearms Act (‘NFA’) and/or the Gun Control Act (‘GCA)” and the Department of Justice’s plan to “subsequently implement a separate process for current possessors of stabilizer-equipped firearms to choose to register such firearms in compliance with the NFA.”
While the proposed rulemaking/guidance has not yet been published in the Federal Register, it is expected to be published in the upcoming weeks and interestingly – seemingly in violation of the law – ATF is only providing a 14 day comment period, at least, pursuant to the draft copy. “Written comments must be postmarked and electronic comments must be submitted on or before [INSERT DATE 14 DAYS AFTER DATE OF PUBLICATION IN THE FEDERAL REGISTER].” It would not surprise me if the proposed rulemaking/guidance is published on December 24th, so that most interested individuals and businesses will be distracted by the holidays and unable to respond in the two week response period. To prevent against these types of shenanigans, the Gun Control Act mandates a 90 day comment period.
As more information becomes known, we will update this blog post or publish new ones, depending on the development.
If you or your company wish to file a comment in support or opposition to a notice of proposed rulemaking/guidance by a federal administrative agency, contact Firearms Industry Consulting Group today to discuss your rights and legal options.
Firearms Industry Consulting Group® (FICG®) is a registered trademark and division of Civil Rights Defense Firm, P.C., with rights and permissions granted to Prince Law Offices, P.C. to use in this article.
Published by Joshua Prince, Esq.
With our 2nd Amendment rights being attacked at both the Federal and State level, and the ATF (Burea of Alcohol, Tobacco, Firearms, and Explosives) trying to close down FFLs (Federal Firearms Licensees) for minor infractions while making FFLs the scapegoat when the ATF's records are inaccurate, I want to take this opportunity to introduce myself. I am one of only a handful of attorneys across the US that practices in the niche area of law known as firearms law. I decided to concentrate my legal practice on firearms law not only because I am a shooter and firearms enthusiast, but also to ensure that our inalienable Right to Keep and Bear Arms is never encroached upon.
I handle cases at the Federal and State level for both FFLs and individuals. At the federal and state levels for individuals, I actively defend the 2nd Amendment of the US Constitution and Section 21 of the PA Constitution, as well as, help individuals with:
- License to Carry Firearms Denials;
- Challenges to Erroneous PICS Denials;
- Relief from Firearms Disabilities;
- Estate Planning Advice;
- Gun/NFA Trusts; and
- 42 USC 1983 Actions for Deprivation of Civil Rights
At both the state and federal levels, I represent FFLs and SOTs throughout Pennsylvania and the US regarding:
- ATF Compliance Inspections;
- Warning Letters and Hearings;
- FFL Revocations;
- Corporate Structure Advice
- Indoor/Outdoor Range Implementation; and
- Forfeiture Proceedings
In following my love for firearms and firearms law, I have taught several Continuing Legal Education (CLE) seminars on Firearms in Estates and Trusts and Firearms Law 101 for several Bar Associations, including Berks, Cumberland, and Dauphin Counties. I also planned and taught several Firearms in Estates CLE classes for the Pennsylvania Bar Institute (PBI).
While at Widener Law School, I was a member of the Widener Law Journal. I wrote an article on the Inaccuracy of the National Firearms Registration and Transfer Record (NFRTR). I also had an article published on Fee Disputes in Workers Compensation cases in the Widener Law Journal, Volume 18, No. 2.
You can often find me posting on several internet forums, including Subguns, Uzitalk, AR15, and PAFOA. I also hold PA Firearms Law classes for local ranges to inform the public on the firearm laws of the Commonwealth.
Following in my father's footsteps, I am also a Board member for the Pottstown Police Athletic League (PAL).
View all posts by Joshua Prince, Esq.
Prince Law Offices Blog 
Thank you keeping us up to date with this bullshit by the ATF.And thank you for everything that you do to fight for our inalienable rights!
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Our forefathers did not intend for its citizens to continue to be required to use musket rifle and musket pistols. They intended for citizens to stay equal or better equiped against tyranny, either from abroad or from within, as be best equiped to protect our families, ourselves and to better provide food for our families. The 2’nd amendment is very clear.
At no time does it care to
Invade on our rights with regards to anything concerning barrel lenght of long or short barreled
Rifle or pistol, any type of butt stocks or rear “so called” arm braces peroid.
The government and ATF
are “as always” trying to impose tyrannical ideology and grow in governmental rule of the
Citizens of America, rather than less government rule of law towards citizens of America with regards to
The constitution and all our amendment rights,
especially the 1’st and 2’nd amendment “rights”.
We may or will in time, be invaded by multi-enemies
By sea and air. Those of us true patriots, because of infringement (with semi-
auto rifles) will fight with one arm tied behind us
with semi auto rifles and pistols against enemies
Using full auto weapons as we try to push back invading enemies from our shores. Statistically more citizens are killed in car wrecks each year by far than anyone killed with a semi-automatic
rifle. By far, the cowards and unintelligent persons in our leadership and the agencies that follow their orders in their attempt to do away with our Second Amendment have neither realized or have forgotten what the true meaning of the Second Amendment rights really stands for. The right to own and bear arms in other countries such as Germany was one of the first steps taken to overcome and dictate to the German people caused manzon men’s of deaths in both World War 1 & 2 I miss the same time and time again in other countries with regards to Communism and socialism which all ultimately lead to tyranny and dictatorship. We are Warrior Patriots of the United States of America and not sheep as they prefer us to become. At what point were the American people given the opportunity to vote for depopulation with regards to China’s weapon of mass destruction covid-19 as evidenced by the FBI meaning to breaking into a facility in Houston and uncovering Chinese scientist attempting to build another weapon of mass destruction of biological warfare at what point were the American people allowed to vote as to whether or not we the American people want to live under the rule of world globalization. The Constitution clearly states that be on States government is supposed to follow the will of the United States of American citizens and not their own will that’s why we don’t have dictators but it appears that that is changing which is why it is so much more important that we maintain our Second Amendment right.
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ATF, let me first let you know the definition of a ban, a ban means NOT ALLOWED and you cannot “permit with a revenue generating permit” something that is going to be or currently banned, it voids logic.
Second, arm braces are for forearms and are not curved or fitted for a shoulder or a cross body firing position from the lower shoulder like rifle stocks.
Third, YOU should not be abusing your power to “change legislation” ATF does NOt have the congressional authority to change or create LAW.
Forth, all of ATF’s actions in creating new “bans” or restrictions for weapons is unconstitutional and thus IllEGAL, are y’all not Americans?
Fifth, stop your wannabe king BS and ripping off Americans by trying to generate revenue by imposing “tax stamps”. Tax stamps are ONLY to generate MORE pretend revenue in taxation. Tax stamps don’t magically make a weapon “safer” or less likely to be stolen in a robbery or home invasion and then used by a criminal to kill someone. Tax stamps are fundamentally ILLEGAL because you are TAXING a RIGHT.
Sixth, may of us SHALL NOT COMPLY with your illegal tyranny and Taxation gouging Americans to use a RIGHT we are suppose to have from Birth in the United States.
Sincerely,
GFY
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Nope…not happening
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Already happened buddy
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Defunde the ATF.
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The ATF is a rogue, corrupt, and unConstitutional agency that needs to be disbanded and every single agent and person that is a part of it needs to be out on trial.
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idiot….. listen too how stupid you sound
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Lenart, you are ignorant for calling Johnny an idiot. The Constitution has provisions for patents to advance science and technology, and the Bill of Rights has the 2nd Amendment. Both allowed the likes of Hawkins, Sam Colt, John Moses Browning etc. to advance firearms weaponry technology.
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Braces vs short barrel rifles anyone that built a pistol legally should not be under scrutiny is all on the law makes that allowed them without a Nfa stamp and Called them pistols. There was a clause that the brace was to be shot off the wrist than again the law makes turned there heads again knowing that the gun is shot off your chest the government has the problem not the law abiding citizens of the USA. One more thing when guns are outlawed only outlaws will own them please believe in the 2 nd amendment. Thanks Larry
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Would going on record, as you suggest contacting you, as just an individual (vs say a corp or biz or industry group) have any real impact or value?
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As an LEO in Texas I will not enforce any such regulation, I will not refer any owners of braces to the ATF, nor does my Agency that managed to pass a 2A sanctuary resolution in our county. As an individual I own such brace “Pistols” and they were purchased legally under ATF’s previous ruling! I will not register them, sell them, remove them, or change barrel length! They will stay as they are. This is still the land of the brave and free men. ATF has no oversight! I will not honor any rule, that is not passed and codified into law by congress. I am running for Sheriff in New Mexico, Dona Ana County, and as a future Sheriff, I will protect the 2A and I will not enforce any red flag laws. Sincerely, Omar Chavez
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The best of luck sir. Now if more sheriffs and Mayors and governments stood by your side a lot of our problems would be solved. In my personal opinion there should be a massive civil and criminal lawsuit taken out against the ATF and anyone that orders them to do the things that they are doing with regard to the massive infringement on our second amendment rights.
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God bless you officer we need a hundred million more like you and we can take this country back away from the corrupt politicians and the corrupt agencies such as the ATF and the FBI.
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There are millions like him. I am a former federal agent/Police Officer myself. If need be I will put my hard learned and earned skills to work to destroy tyranny if it comes knocking.
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First, I support your statement and thank you and wish you luck. As a retired Master Texas Peace Officer as defined by civil statute and TCLEOSE, I would like to advise anyone in Texas that no Texas Peace Officer can legally enforce ATF licensing, papering or tax stamps. If a peace officer, guard, or cop etc approaches you and wants to see your weapon that’s up to you. To see your tax stamp that’s up to you. Demand it, no, not in their designated authority. I’m not saying you won’t make them angry, make them want to take you in or falsely/unconstitutionally detain or arrest you. We used to say you can beat the rap but you can’t beat the ride. Not to mention the delay, inconvenience, cost etc. I support your stance and had the same. Just know in Texas, Peace Officers )police/sheriff etc) don’t have any jurisdiction there.
Two, good luck on your run around Las Cruces. I understand ElPaso has drunk the kool aid and most police and deputies have a chip. I have no knowledge if New Mexico or other states are like Texas as far as jurisdiction on NFA items. If anyone knows it would be good to know.
Another misconception in Texas, Fish and Wildlife or Fish and Game officers have no jurisdiction or right to make traffic stops unless they can go beyond reasonable suspicion and articulate PC that you are a fleeing felon.
Cheers,
X Kop
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Good Man & righteous Patriot!
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This is ABSOLUTELY unacceptable! They can’t determine law and at the least they can’t make millions felons in 14 days! This needs to be struck down hard! This is a big deal, this is the kind of backdoor assaults on the Second Amendment our Founders warned against. Plus they are in “common use”, the NFA is arguably unconsititutional as it is.
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The common thread here is (and has always been) overreach by the government and their lapdogs (ATF).
How do we finally and legally get rid of the ATF, NFA and GCA?
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I think, for the first time in a long time, we will be seeing non-compliance as a form of protest on a large scale. I do not foresee many firearm owners that possess braced firearms, registering, or turning in, said braces.
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I would love that to be true. But i doubt it. Ive come to the conclusion that 90% of gun owners aren’t gonna do shit. There gonna talk talk talk about the constitution and “come and take em” , then want a pistol permit for their rifle on armslist for their “piece of mind”, or immediately hand over their poly 80s when they come to collect them. They are gonna disarm each of us individually cause we wont draw a line in the sand and say, “here, and NO further.”
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If 10 percent do shit, that is far more than enough to stop the batf, they don’t have enough agents no one does. Not agents willing to risk a 1 in 10 chance of dying
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The BATFE has over stayed its purpose and usefulness. It’s original intent as a Law Enforcement Agency, as a Govermental Tool in the fight against criminals, those who go out and commit crimes with guns has turned into a agency that utilizes its authority as a way to procure money from the law abiding citizens. In all my years as a LEO, I have never seen or investigated/Interviewed a person under arrest who based their decision on wether or not to commit a crime on how many inches the barrel of the gun they chose to do it with. And most criminals dont know SBR, SBS and AOW from ATF. It seems that the BATFE is a agency that comes up with these rules soley for the purpose of Justifying Their Existence, While criminals roam the streets victimizing the citizens with guns and then plea bargaining their cases with lenient court officials, the BATFE concerns itself with penalizing the law abiding making them administrated felons by creating laws, that have no effect on criminals nor their activities. You have to ask yourself, is this America or The New World Order! Somebody Help Me Please!
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While I agree with the sentiment, I think we both know that regulation would have come to a quick constitutional challenge and lost primarily on grounds of making an ex post facto law. Even the ninth circuit has begun pushing back on these idiotic regulations which would effect millions of persons. In a way, California is the gun advocate’s best friend for trying to make regulations such as magazine capacity restrictions. I chuckled reading their decision telling the AG of California that he was pushing a law which was inherently racist. BTW, California’s AG has moved on to the anticipated Biden administration. Keep your eyes on Xavier Bacerra in HHS. I expect he will use this position to declare gun violence as a health care emergency.
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I am sick of the NFA, it has never made common sense and we need to work harder to get rid of it.
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The atf itself is an infringment on the 2a any restrictions placed on it or citizens protected under it is unconstitutional and is deemed null and void if i remember correctly just like full auto it was outright banned which infringed on citizens 2 a right time to dismatle and destroy them tbh
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So let me get this straight….. the ATF somehow believes that having a pistol brace somehow magically makes it much more scary? Seriously, Our tax money is going for stupidity like this? Making citizens into criminals through rule making.
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I’ll be honest with you, after reading the article, there are a couple things to be somewhat happy about.
First, the arm brace stupidity has risen to the point where the atf actually publicly printed the factors it uses to make determinations on arm braces. This is a first for transperancy. I wish they were a lot more transparent.
Second, it is not saying they are changing determination of what they have previously determined to be an arm brace, they are saying that some manufacturers have been making claims that are not backed up by issued determination letters.
Third, they are saying they realise that the manufacturers have made these claims and the buyers relied on the manufacturers to sell lawful product and that the buyers shouldnt be prosecuted for the sellers mis statements.
Fourth, they are saying because the buyers bought in good faith they are planning on offering an expedited SBR registration process for those mis classified arm braces and also they wont be charging the nfa $200 making tax.
I’ve been dealing with the atf and nfa branch since 95 and ive seen dick move after dick move from this agency and these agents. Really this situation does not seem like the atf is trying to be dicks, rather they are trying to clarify and address what they consider a problem.
If they do have an expedited SBR registration with no tax, would you honestly consider that to be ‘bad’?
I’m not saying I believe in the mission statement of the atf. I’m not saying I agree they should make changes to ‘arm braces’ regulation. I’m not. I’m just saying I dont think the current direction they are going on this particular issue is ‘bad’.
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…….they are saying they are making pistol braces essentially an nfa item. I didnt see anything talking about only specific braces. This comes on the heels of them raiding poly 80 for selling their frames with a slide kit because whether or not something is a firearm or not is determined by its proximity to other specific objects……we apparently have vastly different views on what constitutes a dick.
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We need to be extremely cautious here. While at first glance a “amnesty” period where a tax tree NFA registration sounds nice effectively it still is a registration. It literally sounds like a disguised attempt to create a registry that will ultimately give them a road map to confiscation one day. Be careful in your assumptions of oh this isn’t so bad. There never is a free lunch.
Plus if they can waive the tax and “expedite” the process it just shows how lame the current NFA registration scheme is then. All this time there has been no good reason then why some of those approvals take well over a year. Its ridiculous.
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Yes it would be bad. register your weapon as an nfa device a you need written permission to take it across state lines. My braced pistol is my best portable weapon. I can not legally transport a rifle sb or otherwise using my ccp license,
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Defund & abolish the ATF
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A legal question. Being that what is being proposed in regards to braces is a “RULE” and not a “LAW”, doesn’t this make a RULE unconstitutional? Per the Constitution all laws are supposed to be proposed and passed by our legislative branch, then either signed or vetoed by the President. Am I wrong?
We have 3 branches of Government. The Executive, the Legislative, and the Judicial. So when did we get an Administrative branch. Though the SCOTUS has ruled otherwise, the ADMINISTRATIVE PROCEDURE ACT (5 U.S. Code CHAPTER 5) is unconstitutional. If this regulation is passed is it possible for affected parties to file a class action law suite? I know 5 U.S. Code CHAPTER 5 has been challenged before but not by millions of Americans at once. If we can get the word out in the firearms community and have other attorneys such as yourself to join the fight, do you think it would gain traction and stand a chance. We could also start fund raising now to pay for your legal fees and whatever other fees are associated for filing with the courts.
As a community and as people who love our freedoms and constitution it is time we rise together, stand together, and fight in the courts with everything we have. Is this something that may be feasible? If so, how can we get started?
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My question is how is the ATF making rules, the are not a legislative body, only an enforcement division. Seems that would be in violation of multiple laws and the constitution it self.
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Are the planning to be good neo-Bolsheviks and wave the $200 tax stamp for those that put them on the unConstitutional NFA registry?
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Support the second amendment foundation, they are constantly filing lawsuits against those who wish to take our rights away.
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ATF Is NOT a legislative body. They are simply the gun police, period. I’m onboard for defunding the ATF! If the ATF paid more attention to Public Safety they wouldn’t have time for politics. Gun walking in the ATF is a pandemic in itself. The DOJ doesn’t want the oversight of ATF for plausible deniability. Review Jay Dobyns case, and in the end he lost. The only case done right, but in the end ATF eats their own. Research other ATF cases Waco; Dallas; Ruby Ridge etc, all failed missions. WACO: ATF and FBI burn to death women and children on U.S. soil and not one Agent is demoted, fired or prosecuted. Absolutely no LEADERSHIP within the ATF! ATF Is fundamentally flawed in regards to Public Safety.
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Disabled persons should sue under the Americans With Disabilities act, which is an actual law unlike these draconian measures.
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One way to go with the rogue ATF. Disband, defund the Gestapo bastards right now. That was considered by congressional leaders after the murder done at Waco . Problem, NO other agency would accept the career govt. agents into any law enforcement (Federal) after their awful record in many places. Of course the (FBI) was in overall charge of all of this. Look at their record and rein them in . They act like , God, they are not. Bust their asses , replace agents as needed before it is too late. Put them out of work! TRC in SC
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It’s not really a rulemaking though, is it? They’re just asking for comments on a guidance document (which doesn’t have the force and effect of law nor is it binding on an agency) so the 14 day comment period is perfectly legal – they don’t have to ask for any comments. That said, I despise the NFA and do have a huge issue with the (cowardly) ATF thinking it’s OK/legal to use (still) vague and non-binding guidance documents to regulate firearms instead of actual detailed and specific regulations. Thanks for uploading the draft notice. Much appreciated.
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While ATF is attempting to contend it is a guidance document, it appears to be more inline with a rule. One can label something whatever they want – it doesn’t mean that it is actually that.
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Sorry but I’m not registering my AR Pistols. The government has far to much reach right now. I took an Oath Of Office when I went into the service and my Oath doesn’t have an expiration date. WOLVERINES!!!!!!!
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Defund & abolish the ATF
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Why are the liberals so against our right to own equal arms to those possessed by the military, and/or any criminals, despite the fact that these military style weapons are statistically used in less than a 10th of a percent of gun voilence.
Why is it that gun violence in democrat controlled cities, with the strictest (unconstitutional) gun control dwarfs no gun control constitutional cities in comparison.
As an example, when the idiot criminal using an illegally obtained ak rifle shot 13 people, 5 of whom sadly died at the onion festival in Gilroy CA, that same weekend in Detroit alone 300 people were shot with hand guns.
Laws that prohibit law biding citizens the right to bear any arms whatever they may be, only serve to make it easier for criminals.
If you read the statements of the founding fathers the true intent of the second ammendment is clear.
First of all the right to bear arms is a God given right, and the second ammendment was written to ensure that right was not infringed on.
Therefore any gun law prohibiting owning any type of weapon is an INFRINGMENT and therefore unconstitutional.
Our founding fathers clearly stated that we have the right to defend ourselves, our state, and country from all enemies both foreign and domestic, including a tyrannical government.
Yes gun technology has produced far more lethal weapons or arms than those in the days of our founding fathers, but even then there were arms capable of firing multiple rounds a minute, and now all these modern arms are obviously possessed by militaries and criminals, the only way to even out the playing field is to maintain said arms availability to law biding citizens also, so as to ensure your right to all the formentioned is maintained.
If a home invaders kick in your door in an unconstitutional gun control city or state, they won’t be obeying any gun control laws, they’ll have automatic weapons with standard mags, and you’ll have 10 round mags and rifles you have to take apart to reload, likewise if they decide you can’t own any arms and start unconstitutional confiscation of said arms.
All under the guise of preventing mass shootings when anyone with a brain knows any idiot planning to do so won’t show up with arms that comply to they’re ridiculous regulations any way.
Since before Trump was elected the democrats have acted like and are criminals, fake Steele dossier, fake impeachment, fake whistleblowers, rigged election, backed by rich globalist like George Soros, they are guilty of treason, want complete control, and to disarm the law biding so we can’t do anything about it, under the guise of public safety which is already non existent in all they’re gun controlled cities and states, and while they’re at it lets refund the police, release violent criminals back onto the streets, open our borders so criminals, terrorists, murderers, gangs, and drugs can enter at will, and while we’re doing that we’ll try to take away your guns so you can’t defend yourself.
The atf has had no problem with bump stocks, pistol braces, and other items in the past, did the constitution and the items mentioned miraculously change this month. NO!
It’s the right to BEAR (that means carry with you in public) ARMS (that’s what soldiers carry into battle, arms, not mechanically castrated versions of them with little non standard magazines, not hunting rifles, real arms just like our military)
No thanks folks, Trump should declare the election unconstitutional, and states should themselves vote.
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Let me start off by saying any gun law is a violation of the constitution. The founding fathers did not put any if, and or buts in the second amendment. The ATF is over stepping its boundaries. We the people are sick of it the ATF has no right to change or make up laws as it sees fit. Back off of our rights.
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Atf can not get away with this first bump stocks now braces next it will be how light your trigger can be than semi automatics and the list goes on.
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The type, function and shape of firearms has no bearing on criminal intent. This is purely harassment of the 99.99% of law abiding gun owners. The NFA is anachronistic, now that crime data is easily compiled and patterns revealed if anything handguns are used in most crimes – but are also used in even mire defensive actions against crime.
An AR15 Pistol, an AR15 SBR are functionally no different and no more dangerous than an AR15 rifle. If anything I’d expect the ATF to delicate these items to better concentrate in real crime.
That is unless they are as corrupt and an enemy of the people of the United States as the FBI, DOJ and CIA have become since Obama.
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My 2nd ammendment rights says I have the right to bare arms. It doesn’t have an asterisk underneath. But it does say SHALL NOT BE INFRINGED. This is against the constitution.
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Looks like it will be published tomorrow with a 14 day comment period!
https://www.federalregister.gov/public-inspection/2020-27857/objective-factors-for-classifying-weapons-with-stabilizing-braces
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Defund the ATF!
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This is just the first steps to infringement of our rights. They are trying to ban a stabilizing braces, in which can be used with there intended purpose to increase the accuracy of the firearm. Which in hindsight can cause less “accidents” such as harm, injury, or death to something or someone other than the intended target. I can’t think of ANYONE who would want essentially featureless firearm that cannot be shot accurately for any purpose sporting or defensively. Now they want to essentially take away optics and other accessories that could be again USED TO shoot the firearm accurately. Optics are not only for “distance”. They aid in target acquisition for persons with less than fair or poor eye sight. But these guys think they are doing “right” and making the world “more safe.” Which in reality all they are doing is making it harder for law abiding citizens to pursue hobbies, ptotection, and sporting purposes such as hunting and other recreation. With all these taxes, acts, and bills only the elite of society will be able to protect, and defend themselves. And that is exactly what is going on, the are stripping the rights, freedoms and possessions of the people who make the country flourish. All because they are afraid of their own tyranny. It’s their tyranny that will cause the people to say “enough” and rise. Everyone just needs to remeber this IS THE “UNITED” STATES OF AMERICA and UNITED WE STAND, DIVIDE WE FALL. And fall we will if these things continue to happen. This country was built on freedom long ago, and it is NOW that they are attempting to take it away. Every voice counts on this one ladies and gentlemen. If this isn’t stopped now then god only knows what will be or will come next. To all that takes the time to read these words thank you for your time and have a great day
~Signed A Concerned Patriot
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A more practical question here: Does anyone know if a firearm classified as “other” is subject to the ATF Rulemaking or is it just AR/AK pistols? For example is a POF Constable (Other) with an overall length of 28″ (muzzle to end of buffer tube) with 12.5″ barrel and brace (not included in overall length) fall under the new ATF rule?
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The ‘criteria’ laid out in the document is so arbitrary that choosing 10 firearm enthusiasts, and 10 big city people unfamiliar with firearms would result in different determinations if the firearm is a pistol with a brace or a short-barreled rifle. Policymaking should be clear and easily interpreted. The ATF should not impose a significant burden upon American citizens and American industry. We should be ensuring our industries thrive and the laws and policies are clear and concise. Firearm enthusiasts, and non-firearm citizens should be able to clearly interpret ATF criteria and rulings. The passage of these rules does not enhance public safety. Instead, it creates an unnecessary burden on American citizens and industry. The wrong interpretation results in a FELONY!!!! This is not acceptable.
That was my response on the Federal Register
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