You NEED to comment on new rule change proposal

[Expat]

Finally did it.

 

[KellyinAvon]

That copy/pasted better than I thought it would!

Got this from a bud who is in the Ohio Gun Collectors. Has a draft to send to ATF if you haven't already.

7 December is coming soon.

Dear Members and Collectors: We need your help on or before December 7, 2023, to contact your US Senators and Representatives as well as The Bureau of Alcohol, Tobacco, Firearms and Explosives (“ATF”). The ATF is proposing new regulations that change who is required to have a Federal Firearms License (“FFL”) in order to sell a firearm. These regulations have not been adopted and with your help the regulations may be rejected. The proposal provides rebuttable presumptions of who is selling firearms to “predominately earn a profit” and thus are “engaged in business” and they are a dealer who must be licensed. What does all of this mean? The Proposal is that a person must be licensed if they sell firearms with intent to predominately earn a profit. In the Proposed regulations this is defined to include tagging a firearm with a sale price, renting a table at a gun show, or maintaining records regarding purchased and sold prices. Further, offering firearms of a similar kind or type for sale. These are rebuttable presumptions. What a “rebuttable presumption” means is that if ATF establishes one of these facts, such as renting a table at a gun show that offered firearms for sale, one is presumed to be a firearms dealer, who is required to have an FFL license. The burden to prove otherwise then moves to the seller to establish that they are not “engaged in business”. These presumptions are for civil, not criminal proceedings. These proposed changes in the regulations have come from a directive of the President and the Attorney General. They are asserting that these changes are proper based upon changes in federal law enacted in the Bipartisan Safer Communities Act (the “BSCA”). The BSCA does not provide for these presumptions. BSCA was passed by Congress as law, the proposed regulations are being put forth by the administration through ATF as a “reasonable interpretation” of the BSCA. We disagree. The proposal if enacted is not good news for gun shows or OGCA. Exactly how everything would fall out is not known. What is OGCA doing about this: OGCA has prepared and sent detailed information regarding the proposed rule to collector organizations, show promoters, and other interested parties throughout the county. OGCA also requested these entities submit objections to the proposed rules before the deadline of December 7, 2023 and provided a detail explanation of objections that could be made. OGCA has also requested these entities contact their Congressional Representatives and US Senators to voice their concern and provided information for making those complaints. OGCA is asking you to object to the proposed rule and voice your objection to your Congressional Representatives and US Senator (more information provided below) and spread the word that this proposed regulation is not acceptable. OGCA will be presenting a detailed objection to the proposed rule and communicating its objections to the Ohio Congressional Representatives and US Senators. It must emphasized that these regulations have not been adopted and if they are adopted it will take some time. So nothing has changed with regard to the regulations for the November or January OGCA meetings. Please be respectful in all communications to others regarding this matter. If you wish to review detailed information regarding the proposed rule, please click on this link: Alert – Ohio Gun Collectors Association (ogca.com) Below is a draft objection to the proposed rule should you wish to submit it to ATF. We also suggest that you also send a copy of your objections to your federal representatives, their contact information is available the links below. Links that provide contact information for your US Senators and Representative https://www.senate.gov/senators/senators-contact.htm https://www.house.gov/representatives/find-your-representative Proposed objection for your submission to ATF RE: ATF 2022R-17, proposed rule I am writing to object to several provisions of the proposed 27 CFR Part 478. The presumptions set forth that one is engaged in the sale of firearms and needs an FFL for doing things such as renting a table at a gun show, placing a price tag on a firearm, keeping records of purchase and sale prices of guns, and selling guns of the same manufacture or like new, is not proper and contrary to the provisions of law that specifically provides for occasional sales for gun collectors and hobbyist. Sales and purchases by non-dealers were not prohibited by the Bipartisan Safer Communities Act. Had that been the intent of the BSCA it would have so stated. It is not proper to take actions by regulation that go far beyond what Congress provided in law. The provisions in paragraph (c) setting forth presumptions of “engaged in business” and the revisions setting forth presumptions of “intent to earn a profit” are not supported by the language of BSCA, and should not be adopted. Use this Link to submit electronically opposition to the proposed Rule to ATF, you can copy and paste the proposed objection above and submit it through this link: https://www.regulations.gov/commenton/ATF-2023-0002-0001​

The Ohio Gun Collectors Association PO Box 670406 Sagamore Hills, OH 44067 (330) 467-5733 ogca@ogca.com www.ogca.com​

 

[DDadams]

One week left.

Please check @KellyinAvon 's post for a pre-made letter you can comment if you aren't a wordsmith.

 

[KellyinAvon]

That copy/pasted better than I thought it would!

Got this from a bud who is in the Ohio Gun Collectors. Has a draft to send to ATF if you haven't already.

7 December is coming soon.

Dear Members and Collectors: We need your help on or before December 7, 2023, to contact your US Senators and Representatives as well as The Bureau of Alcohol, Tobacco, Firearms and Explosives (“ATF”). The ATF is proposing new regulations that change who is required to have a Federal Firearms License (“FFL”) in order to sell a firearm. These regulations have not been adopted and with your help the regulations may be rejected. The proposal provides rebuttable presumptions of who is selling firearms to “predominately earn a profit” and thus are “engaged in business” and they are a dealer who must be licensed. What does all of this mean? The Proposal is that a person must be licensed if they sell firearms with intent to predominately earn a profit. In the Proposed regulations this is defined to include tagging a firearm with a sale price, renting a table at a gun show, or maintaining records regarding purchased and sold prices. Further, offering firearms of a similar kind or type for sale. These are rebuttable presumptions. What a “rebuttable presumption” means is that if ATF establishes one of these facts, such as renting a table at a gun show that offered firearms for sale, one is presumed to be a firearms dealer, who is required to have an FFL license. The burden to prove otherwise then moves to the seller to establish that they are not “engaged in business”. These presumptions are for civil, not criminal proceedings. These proposed changes in the regulations have come from a directive of the President and the Attorney General. They are asserting that these changes are proper based upon changes in federal law enacted in the Bipartisan Safer Communities Act (the “BSCA”). The BSCA does not provide for these presumptions. BSCA was passed by Congress as law, the proposed regulations are being put forth by the administration through ATF as a “reasonable interpretation” of the BSCA. We disagree. The proposal if enacted is not good news for gun shows or OGCA. Exactly how everything would fall out is not known. What is OGCA doing about this: ​ OGCA has prepared and sent detailed information regarding the proposed rule to collector organizations, show promoters, and other interested parties throughout the county. OGCA also requested these entities submit objections to the proposed rules before the deadline of December 7, 2023 and provided a detail explanation of objections that could be made. OGCA has also requested these entities contact their Congressional Representatives and US Senators to voice their concern and provided information for making those complaints. OGCA is asking you to object to the proposed rule and voice your objection to your Congressional Representatives and US Senator (more information provided below) and spread the word that this proposed regulation is not acceptable. OGCA will be presenting a detailed objection to the proposed rule and communicating its objections to the Ohio Congressional Representatives and US Senators. It must emphasized that these regulations have not been adopted and if they are adopted it will take some time. So nothing has changed with regard to the regulations for the November or January OGCA meetings. Please be respectful in all communications to others regarding this matter. If you wish to review detailed information regarding the proposed rule, please click on this link: Alert – Ohio Gun Collectors Association (ogca.com) Below is a draft objection to the proposed rule should you wish to submit it to ATF. We also suggest that you also send a copy of your objections to your federal representatives, their contact information is available the links below. Links that provide contact information for your US Senators and Representative https://www.senate.gov/senators/senators-contact.htm https://www.house.gov/representatives/find-your-representative Proposed objection for your submission to ATF RE: ATF 2022R-17, proposed rule I am writing to object to several provisions of the proposed 27 CFR Part 478. The presumptions set forth that one is engaged in the sale of firearms and needs an FFL for doing things such as renting a table at a gun show, placing a price tag on a firearm, keeping records of purchase and sale prices of guns, and selling guns of the same manufacture or like new, is not proper and contrary to the provisions of law that specifically provides for occasional sales for gun collectors and hobbyist. Sales and purchases by non-dealers were not prohibited by the Bipartisan Safer Communities Act. Had that been the intent of the BSCA it would have so stated. It is not proper to take actions by regulation that go far beyond what Congress provided in law. The provisions in paragraph (c) setting forth presumptions of “engaged in business” and the revisions setting forth presumptions of “intent to earn a profit” are not supported by the language of BSCA, and should not be adopted. Use this Link to submit electronically opposition to the proposed Rule to ATF, you can copy and paste the proposed objection above and submit it through this link: https://www.regulations.gov/commenton/ATF-2023-0002-0001​

​ ​

The Ohio Gun Collectors Association PO Box 670406 Sagamore Hills, OH 44067 (330) 467-5733 ogca@ogca.com www.ogca.com​

Like @DDadams said, if you haven't commented, copy/paste/submit.

 

[DDadams]

One day left people, tomorrow is it.

 

[Thor]

Done, just under the wire.

 

[indyblue]

Geez, this form is contradictory. How do I submit without "personally identifiable information"? First & Last names required for the form to submit:

 

[KomboJoe]

Geez, this form is contradictory. How do I submit without "personally identifiable information"? First & Last names required for the form to submit:
View attachment 317330

Not very clear is it. The name is required to leave a comment because of some law or something, but the comment itself hides your last name. They just don't want you to put it in the comment itself.

 

[indyblue]

Not very clear is it. The name is required to leave a comment because of some law or something, but the comment itself hides your last name. They just don't want you to put it in the comment itself.

Yeah, I reread it a few times and finally figured it out. It still doesn’t sit well. Having to put my name in there.

 

[KomboJoe]

Yeah, I reread it a few times and finally figured it out. It still doesn’t sit well. Having to put my name in there.

It would be nice if they would allow anonymous, but I think they do it to get a more accurate count of unique commenters or something like that.

 

[DadSmith]

Gun Control Advocates Flood Comments Section In Support Of Proposed ATF Rule To Restrict Gun Sales | ZeroHedge

ZeroHedge - On a long enough timeline, the survival rate for everyone drops to zero

www.zerohedge.com

 

[Basher]

**** the ATF.

 

[Ark]

Everybody remember to thank Todd Young for voting for the law that ended the INGO classifieds.

 

[indyblue]

ATF Accepts 40,000 More Petitions Against Background Check Rule

The ATF, under pressure from GOP House members, agreed to accept 40,000 additional petitions against the agency's background check rule.

www.breitbart.com

 

[DadSmith]

ATF Accepts 40,000 More Petitions Against Background Check Rule

The ATF, under pressure from GOP House members, agreed to accept 40,000 additional petitions against the agency's background check rule.

www.breitbart.com

How can they make law?
There is no law stating you need a background check for private sales.
This will be challenged, and I believe overturned.

 

[Basher]

Everybody remember to thank Todd Young for voting for the law that ended the INGO classifieds.

**** Todd Young, too.

 

[Basher]

How can they make law?
There is no law stating you need a background check for private sales.
This will be challenged, and I believe overturned.

I don’t know HOW MANY TIMES this has to be stated before SOMEONE pulls their head out of their ass and starts dick-kicking the ATF every time they try to pull this ****. Let me yell it for the deaf geriatric pedos in the back in D.C.:

THE. ATF. CANNOT. MAKE. LAWS.

Every time they try to pull this ****, everyone involved needs to get hit with a $50,000 fine. Do it twice, and you lose your job. ****’s gotta stop.

 

[Mgderf]

I don’t know HOW MANY TIMES this has to be stated before SOMEONE pulls their head out of their ass and starts dick-kicking the ATF every time they try to pull this ****. Let me yell it for the deaf geriatric pedos in the back in D.C.:

THE. ATF. CANNOT. MAKE. LAWS.

Every time they try to pull this ****, everyone involved needs to get hit with a $50,000 fine. Do it twice, and you lose your job. ****’s gotta stop.

They need to go to jail.

 

[JAL]

I filed two different comments. Should have mentioned this here that people can file multiple comments . . . but they shouldn't be identical or nearly so. I started with a template and then rewrote them to make them different enough to address different issues with the rule. Not of use now -- but something useful in the future. Submitting the same one over and over doesn't do anything productive.

Regarding copy, paste, and submit, it's easy, but Fed Agencies go through and bundle them, dumping most into the bit bucket, unless they want to count the number to justify what they're doing. The bottom line is making all submissions unique enough that they cannot do that. It's my impression that Brady, Everytown, Moms Demand, and others use the copy, paste and submit to generate an avalanche. Just like they pack legislative hearing rooms in their T-shirts, loudly booing, hissing and clapping, using their negative lengthy remonstrances to consume someone's speaking time. I've been at public meetings where opposition groups will attempt that . . . the heckler's veto.

 

[DDadams]

I really wish I had thought of the idea my girlfriend proposed to me earlier about this 'rule'

All sorts of the LGBTwg2udjwb3h community getting involved in 2A stuff lately and I think if someone real, or maybe not even real, pointed out the "issues this bill will cause to the trans community" it would actually sway some of the brain-rotted lefties. Any time they hear something is "hurting" their new pet community they jump at it.

I need to find a way to contact someone big on YouTube or Twitter, to at least try to get someone to give her idea a shot.