Comment on FR Doc # 2013-21661


I oppose these proposed regulation changes for the following reasons:

1. The Chief Law Enforcement Officer (CLEO) certification is antiquated and a gross waste of resources. It predates the National Instant Criminal Background Check System (NICS) and allows for CLEOs to arbitrarily deny law-abiding citizens with no criminal record the right to possess legal NFA items.

2. A proof of citizenship is not a requirement to vote or to obtain a federal tax return, it should not be a requirement to legally transfer and possess an NFA item.

3. Requiring fingerprints and photographs of every “responsible person” on an NFA trust, or part of a corporation or LLC carrying NFA items, is an unacceptable invasion of privacy. If that personal information were obtained by the local, state, or federal government, it could be made public or abused. Unless a person is suspected of a crime, such information should not be forcibly extracted from them.

4. NFA trusts are often used to ensure that a child may inherit the assets of the trust from a deceased parent. They are valuable tools for estate planning, and beneficiaries should not have to submit to these violations of their civil liberties simply because they have inherited private property.

5. These proposals will have absolutely no impact on crime. Since the National Firearms Act was passed in 1934, there have been 2 murders with legally obtained, registered NFA items. No criminal is going to spend the $300 to $1000 to form an NFA trust, pay the ATF $200 for a tax stamp for each NFA transfer, submit a Form 1 or Form 4, wait 5 to 9 months for approval, pay upwards of $10,000 for a machine gun and upwards of $2000 for a silencer, and finally complete the transfer with a local SOT Federal Firearms License holder before committing a crime.

These proposals have nothing to do with curbing gun violence and have everything to do with forcing law abiding citizens to navigate a labyrinth of bureaucracy to obtain NFA items or surrender their right to possess them. There are already numerous laws regulating the transfer and possession of NFA items, we simply do not want or need more. I oppose these proposed regulation changes in their entirety and I implore the Bureau of Alcohol Tobacco Firearms and Explosives to retract this proposal completely and indefinitely.
Comment Period Closed
Dec 9 2013, at 11:59 PM ET
ID: ATF-2013-0001-3430
Tracking Number: 1jx-8901-arv5

Document Information

Date Posted: Dec 5, 2013
RIN: 1140-AA43
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Submitter Information

Submitter Name: adam vuksich