Firearms Industry Consulting Group ("FICG"), a division of Prince Law Offices, P.C., continues to present evidence and argument to ATF in opposition to its proposed rule 41P. FICG drafted and filed a Comment on behalf of David M. Goldman (ATF-2013-0001-1899) that set forth arguments echoed in many subsequently-filed comments. FICG submitted its own Comment (ATF-2013-0001-8364 … Continue reading FICG Files Supplemental Comment in Opposition to ATF 41P
Category: ATF
Was Your Voice Heard on ATF 41P?
Have you confirmed that your comment is in the docket? If not, you may want to act now to ensure it is properly processed. As readers of this Blog are well aware, on September 9, 2013, ATF published a proposed rule that would restrict the ability to make and transfer firearms regulated under the National … Continue reading Was Your Voice Heard on ATF 41P?
ATF’s Appropriation Bill May Not Be As Devastating As First Thought
On Friday, I posted about ATF’s New Devastating Appropriation Bill – Previous Industry Protections Appear to be Lost. It appears that I may have been in error that those protections were lost, given a previous Governmental Accountability Office (GAO) determination and futurity language being included in the Consolidated and Further Continuing Appropriations Act, 2013. In … Continue reading ATF’s Appropriation Bill May Not Be As Devastating As First Thought
ATF’s New Devastating Appropriation Bill – Previous Industry Protections Appear to be Lost
See January 20, 2014 Updated Article on ATF’s Appropriation Bill May Not Be As Devastating As First Thought.On January 15, 2014, the Congress approved H.R. 3547 - the "Consolidated Appropriations Act of 2014," which is now awaiting the President's signature. The Consolidated Appropriations Act of 2014 seemingly removes key protections for the Firearms Industry.For those unfamiliar, … Continue reading ATF’s New Devastating Appropriation Bill – Previous Industry Protections Appear to be Lost
ATF’s New Shenanigans with Electronic Acquisition and Disposition Records – Who’s Ready to Challenge Them?
Recently, the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) announced ATF Ruling 2013-5, regarding requirements for implementing and maintaining electronic Acquisition and Disposition records that Federal Firearms Licensees must keep, without any opportunity for Notice and Comment, in direct violation of the Administrative Procedures Act (APA), and invalidated a number of previously approved variances, … Continue reading ATF’s New Shenanigans with Electronic Acquisition and Disposition Records – Who’s Ready to Challenge Them?
Warning to All FFLs: ATF is Contemplating Another Rulemaking
We've barely had an opportunity to catch a breath since the deadline to file comments in ATF's rulemaking 41P related to the making and transfer of NFA firearms but all Federal Firearms Licensees ("FFLs") and those interested in seeing the local FFL not driven out of business need to be aware that ATF has yet … Continue reading Warning to All FFLs: ATF is Contemplating Another Rulemaking
FICG Files Comment in Opposition to ATF – 41P
As many of our viewers are aware, Firearms Industry Consulting Group, a division of Prince Law Offices, P.C., has spearheaded the opposition to ATF's most recent rulemaking proposal, ATF-41P. Yesterday, we filed our formal Comment in opposition to ATF 41P. With exhibits, it is over 500 pages. You can download a copy here. As we … Continue reading FICG Files Comment in Opposition to ATF – 41P
ATF 41P: IT’S NOT TO LATE TO CONTACT SBA
The SBA is actively examining whether ATF improperly certified compliance with the Regulatory Flexibility Act. If you are the CLEO of a small jurisdiction or a small business FFL, SBA needs to hear from you NOW. When ATF first announced that it planned to publish the proposed rule that triggered the current rulemaking ATF 41P, … Continue reading ATF 41P: IT’S NOT TO LATE TO CONTACT SBA
Are ATF’s Newly Approved Electronic eForms Legal? The Shocking Answer
Recently, I have seen a number of people posting approved eForm Applications (Form 1's), which had me greatly concerned given the translucent nature of the newly utilized electronic stamp. After receiving these approved eForm Applications by email, some of the applicants have called the NFA Branch and been told that they will not be receiving … Continue reading Are ATF’s Newly Approved Electronic eForms Legal? The Shocking Answer
New staff hirings at the NFA Tech Branch
by Ian K. Friedman, Esq. It has been reported by one of the moderators at the AR-15.com message board (who covers NFA sub-forums) that there has been a significant amount of new hirings recently at the NFA Branch (which handles approvals for Tax Stamps for NFA items). The moderator “tony_k” reported that, “There now are … Continue reading New staff hirings at the NFA Tech Branch
Prince Law Offices Blog 