Operation Reticent Recall – Solvent Traps and Forced Reset Triggers

As many of our readers will already know, 2022 has been a busy year for the ATF, ramping up FFL revocations, sending Warning Notices to customers of Diversified Machine, and now seemingly going after Forced Reset Triggers (FRTs). While details are still scarce, over the last 2 weeks we have seen an increased number of clients seeking advice relating to FRT’s.

To recap, earlier this year ATF sent an open letter to Federal Firearms Licensees stating their determination that “some” FRTs are “firearms” and “machineguns” as those terms are defined by the National Firearms Act and Gun Control Act. ATF was not specific about which FRTs met that definition, instead suggesting “[i]f you are uncertain whether the device you possess is a machinegun as defined by the GCA and NFA, please contact your local ATF Field Office.” Since that time, ATF has made no public statements I’m aware of or otherwise clarified its position on which FRT’s it takes issue with.

Now, we have learned that ATF is sending Warning Notices (included below) to individuals who have purchased FRT’s on GunBroker from the user “rifleremedy2000,” but it’s not clear how ATF has acquired purchaser records or whether ATF itself is operating the account. It appears that ATF’s contact with these purchasers is part of “Operation Reticent Recall,” a name we learned from the top of an “Interview Questionnaire” that has been sent to some of our clients. Not sure if the agency as a whole would be happy about that, because it appears to be a quick guide for an agent’s questioning, but nonetheless, it seeks information regarding “solvent traps,” “solvent trap parts and accessories,“ and “Forced Reset Trigger[s],” with questions like:

How did you learn of/locate the seller?

What was your payment method?

How was the package labeled?

What was the intent/purpose behind purchasing the item(s)?

Was the “solvent trap” drilled out prior to receipt? If upon inspection the “solvent trap” is drilled out, ascertain by whom it was drilled and when.

Did the seller indicate that an approved ATF Form 1 (Application to Make and Register a Firearm) was required prior to purchasing/receiving the item or otherwise state that receipt/possession of the item(s) was governed by provisions of the National Firearms Act?

Are you aware of other persons (or have you referred other persons) who have purchased similar items from the seller (if so, please attempt to identify the additional parties)?

As it appears ATF is taking a more aggressive approach to solvent traps and FRTs, remember that you should not speak to ATF or any other law enforcement without an attorney, and you should NEVER consent to any searches.

If you or someone you know has been contacted by ATF or is seeking advice relating to Forced Reset Triggers and would like to speak with an attorney about your rights and obligations, contact us today!