User Panel
User Panel
User Panel
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Posted: 9/24/2013 5:51:22 PM EDT
[#1]
An example comment to work with:
"Requiring a CLEO sign off is not a true background check. It allows for CLEOs to deny LEGAL OWNERSHIP for arbitrary reasons. Yes it happens all the time. Background checks that happen with the existing trust process is a background check based on a "shall issue," meaning shall if the individual passes. Requiring CLEO adds the arbitrary "if I want to issue" element and many legal law abiding people will be denied because a local official has personal or political objections. Again, that would not be a true background check. A "CLEO notification only" (along with finger prints, pictures, etc...) would still maintain the existing background check and at the same time, make CLEOs aware of whats in their area.
Please do not implement a CLEO requirement for trusts. It will be abused by local officials/police to deny a law abiding citizen the legal right to own a suppressor (It has and does happen all the time)." |
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Posted: 9/24/2013 5:56:01 PM EDT
[#2]
HIT! Should be a firemission
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Posted: 9/24/2013 5:58:13 PM EDT
[#3]
Hit
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Posted: 9/24/2013 6:15:06 PM EDT
[#4]
Quote HistoryQuoted:
Like I said in the other thread about this.....someone write me up something halfway decent and I'll send it in. Numbers are far more important than persuasive arguments in this case. A very simple "This is completely unnecessary and simply another example of overreaching to create solutions to problems that do not exist." is infinitely better than not doing something because of the lack of something elegant to say. |
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Posted: 9/24/2013 6:19:58 PM EDT
[#5]
Quote HistoryQuoted:
HIT! Should be a firemission *Thread title edited* Done. |
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Posted: 9/24/2013 6:25:14 PM EDT
[#6]
Any chance there's a moderator who could pin this?
At least pin it until December 9? |
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Posted: 9/24/2013 6:31:17 PM EDT
[#7]
Quote HistoryQuoted:
Any chance there's a moderator who could pin this? At least pin it until December 9? +1 |
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Posted: 9/24/2013 6:32:57 PM EDT
[#8]
Hit it. Sent in my comments on it.
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Posted: 9/24/2013 6:34:12 PM EDT
[#9]
Quote HistoryQuoted: Any chance there's a moderator who could pin this? At least pin it until December 9? Or pin the original thread.... |
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Posted: 9/24/2013 6:39:39 PM EDT
[#10]
Quote HistoryQuoted:
Meh. They're going to do what they want to do regardless of how many comments or letters are sent their way. According to this legal blog, comments do have some weight in the process. This guy has been writing quite a bit about the process so far, take a look at his page! |
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Posted: 9/24/2013 6:40:10 PM EDT
[#11]
Quote HistoryQuoted:
Or pin the original thread.... Quote HistoryQuoted:
Quoted:
Any chance there's a moderator who could pin this? At least pin it until December 9? Or pin the original thread.... I honestly don't care which one they pin, but the word needs to get out there. Like it or not, we have to have the same mentality as the gun grabbers about this; fight for every inch. They know they can piecemeal our rights out of existence one little bit at a time. Even if this is a fight we lose, we should not and cannot afford to just roll over and take it. Make them work for it. |
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Posted: 9/24/2013 6:42:00 PM EDT
[#12]
Quote HistoryQuoted:
Hit with this: The more you impose your useless regulations that do nothing to deter crime and only serve to infringe on the freedoms of productive members of society the more people will decide to stop complying with what is already an unconstitutional bureaucracy. Leave middle America alone. When was the last time a NFA trust weapon was used in a crime? These political games are pathetic. Apparently you have forgotten your oath to uphold the Constitution. As a Peace Officer I have not forgotten mine. Ridiculous red tape will do nothing more than to compress a powder keg that you have been dangerously close to exploding already. NFA regulations should be loosened or done away with altogether as they serve no functional purpose in these times. I do say this from the bottom of my heart and with all sincerity - You may all go to hell. Do you think I get an extra star for each one of these I've done since the first time my name appeared on their list? 
yeah, telling them to GTH is definitely going to help our cause. 
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Posted: 9/24/2013 6:59:16 PM EDT
[#13]
i just left my comments.
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Posted: 9/24/2013 7:00:27 PM EDT
[#14]
Hit and posted picture to fb.
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Posted: 9/24/2013 7:15:02 PM EDT
[#15]
Quote HistoryQuoted:
i just left my comments. Quote HistoryQuoted:
i just left my comments. Quoted:
Hit and posted picture to fb. Don't stop there. Get friends to comment. Call relatives. We need to spread this around and get as many comments opposing these proposals in before December 9th. |
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Posted: 9/24/2013 7:15:51 PM EDT
[#16]
Hit and bump
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Posted: 9/24/2013 7:24:57 PM EDT
[#17]
Quote HistoryQuoted:
Any chance there's a moderator who could pin this? At least pin it until December 9? +1 |
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Posted: 9/24/2013 7:25:28 PM EDT
[#18]
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Posted: 9/24/2013 8:18:14 PM EDT
[#19]
Comment on Proposed Rule
ATF #41P TL; DR: This text attacks ATF's cost assumptions. Forcing ATF to re-evaluate their costs may push the proposed rulemaking over some various cutoffs and force additional delay and rulemaking procedures. Feel free to steal or critique. SUMMARY OF COSTS AND BENEFITS ATF is required to evaluate the costs of proposed regulations in order to adhere to various aspects of federal law and procedure regarding rulemaking. ATF has failed to adequately consider possible costs associated with the proposed rule making. The following review identifies areas for additional study and justification to ensure compliance with the Small Business Regularory Enforcement Fairness Act of 1996 and the Unfunded Mandates Reform Act of 1995. NUMBER OF RESPONSIBLE PERSONS PER ENTITY Section IV.A.2 states: “ATF estimates that each legal entity has an average of two responsible persons, an estimate that is based on ATF's review of 39 recent randomly selected paper (hardcopy) applications for corporations, LLCs, and trusts. ATF welcomes comments from the industry and other members of the public regarding the accuracy of its assumptions and estimates. ATF has not substantiated a reasonable estimate for the number of reasonable persons per entity. This is extremely significant as almost all other costs in the proposed rulemaking are derived from this figure. In Table A, ATF states that 40,700 legal entities filed applications in CY 2012. In order to generate a sample with a 5% confidence interval to 99% certainty, ATF would need to sample 655 legal entities. ATF’s survey of 39 randomly selected applications has a margin of error of around +/- 20% and is far too small to draw any conclusions on. ATF should sample at least 655 legal entities. Additionally, ATF has not attempted to determine how many legal entities add responsible persons after filing initial hard copy paperwork. For example, many corporations likely establish the corporate ownership with one or two owner/operators or managers, and then add officers as the enterprise expands. Likewise, many trusts established by families likely add responsible persons as the family grows in size over time. By examining only CY12 hardcopy submissions, ATF has introduced significant sample bias and again skewed their estimate of the size of a typical legal entity, which as described above has significant effects for all derived expenses. AVERAGE HOURLY COMPENSATION ATF used a compensation of $30.80 per hour based on average salary data. However, firearm owners in general and NFA owners in specific may have different salaries from the American population in general. ATF should justify the assumptions used in its salary estimates, which are especially critical as most costs are derived from this figure. For example, the National Shooting Sports Foundation found that the majority of Modern Sporting Rifle (AR-15 pattern) owners have an income exceeding $75,001 per year, and a quarter of owners have annual salaries exceeding $110,000 per year. This equates to hourly wages significantly in excess of ATF’s calculations. The survey is available online at http://www.nssf.org/msr/PDF/NSSF_MSR_Report2010.pdf. A 2010 Gallup exit poll found that gun owning voters had educational attainment rates significantly above the average population. 33% were college graduates, and 32% reported post-graduate study. In contrast, only about 30% of Americans are college graduates and only 11% have a postgraduate degree. Educational attainment is often correlated with income. ATF should justify its use of an average salary of $30.80 per hour, or utilize salary figures which reflect the majority of NFA owners. An industry group such as the NSSF should be able to assist in providing such data. AVERAGE HOURLY COMPENSATION ATF used a compensation of $30.80 per hour based on average salary data. However, firearm owners in general and NFA owners in specific may have different salaries from the American population in general. ATF should justify the assumptions used in its salary estimates, which are especially critical as most costs are derived from this figure. COST OF DOCUMENTS TO ESTABLISH EXISTENCE OF LEGAL ENTITY ATF used a sample of 50 applications to determine that the average legal entity application consists of 15 pages. As discussed above, a statistically significant sample would consist of 655 legal entities. ATF should sample a relevant number of entities to justify its estimate of 15 pages for copying expenses, or explain why this calculation should be based off of an arbitrary and statistically irrelevant sample. COST OF FINGERPRINTS ATF assesses that the cost of fingerprints is based on one hour of time. In many areas, only law enforcement provides fingerprinting services on ATF-approved hard copy FBI forms. This service is often only provided during business hours. Having fingerprints taken often requires the responsible person to take an entire day or at least half day off of work. For example, in my locality, fingerprints are only done for the public during a few hours each week during business hours. ATF should increase the time estimate from 60 minutes to four hours to reflect the reality that many applicants will need to take at least a half day off of work to obtain fingerprints in the ATF approved manner, or justify why an arbitrary estimate of 60 minutes was selected. Alternatively, ATF could consider allowing fingerprints to be submitted in an alternative manner, or utilize other proof of identity such as a social security number, concealed weapons permit, or other documentation. COST TO STATE AND LOCAL AGENCIES ATF estimated the time to review applications as 30 minutes. ATF has provided no justification to support this estimate. ATF should sample a statistically significant sample of Chief Law Enforcement Officers to determine actual review times. Some states such as Alaska have required CLEOs to sign off on these applications under penalty of law. CLEOs must therefore dedicate time and resources to fulfill these requirements. This represents a significant unfunded mandate on state and local governments. COSTS FOR A LEGAL ENTITY TO OBTAIN CLEO CERTIFICATE ATF estimates that the time needed for a responsible person to procure a CLEO certificate is 100 minutes. ATF has provided no justification of substantiation for this cost. ATF should sample a statistically relevant number of NFA item owners and determine the actual time to obtain CLEO signoff. Additionally, ATF should consider additional costs associated with the CLEO certificate beyond the applicant’s time. Some CLEOs impose arbitrary requirements to obtain the certificate such as acquisition of an FFL03 C&R license, Concealed Weapons Permit, and so on. Other CLEOs will not sign off for persons who are not personally known to them and their department, and costs to obtain the certificate may include attendance at police fundraisers, volunteer service with the department, and so on. Finally, a significant number of CLEOs are openly hostile to the idea of any citizen ownership of firearms, much less NFA items. The costs associated with CLEO sign off in these jurisdictions may be significant and include contributions to political campaigns, legal fees to retain an attorney, and so on. ADDITIONAL COSTS ATF has not evaluated the cost of this regulation on businesses or federal firearms licensees. The predictable impact of the rulemaking is to reduce sales of NFA items due to additional restrictions. This will impact federal firearms licensees and manufacturers. It will also likely impact the secondary market for resale of these items. ATF should address the probable impact of sales reduction to lawful citizens, and the effect on the secondary market. BENEFITS OF BACKGROUND CHECKS FOR RESPONSIBLE PERSONS ATF has failed to articulate any significant benefits to this policy. ATF highlighted two applications in which trustees were convicted felons. This transfer was not completed. ATF has provided zero evidence of NFA items acquired using legal entities by prohibited persons used in actual crimes. ATF has also failed to conduct any balance of the proposed costs with benefits. Even using ATF’s estimates of the cost of the regulation, which I feel are low and unsubstantiated, the cost of the rule making is expected to be in excess of $15 million per year. A 2010 Iowa State survey found that the average aggravated assaults costs $145,379 in damages and a murder is approximately $17 million. While every life is precious, and violent crime is a moral blight, a rulemaking should objectively compare costs and benefits. ATF has not presented evidence that any violent crimes, much less one as serious as murder, have occurred using NFA items obtained by a legal entity which would be prevented by the proposed rulemaking. The costs of the proposed rulemaking significantly exceed those of the probable benefits. ATF should provide additional substantiation of the probable benefits which can be expected by imposing the burdens of this rulemaking. |
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Posted: 9/24/2013 8:23:31 PM EDT
[#20]
Quote HistoryQuoted:
I just got a SBR form 1 (on a trust) back after 7 months. Congrats. I still got two suppressor stamps due that were sent in mid-January. 
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Posted: 9/24/2013 9:31:53 PM EDT
[#21]
Quote HistoryQuoted:
Comment on Proposed Rule ATF #41P TL; DR: This text attacks ATF's cost assumptions. Forcing ATF to re-evaluate their costs may push the proposed rulemaking over some various cutoffs and force additional delay and rulemaking procedures. Feel free to steal or critique. SUMMARY OF COSTS AND BENEFITS ATF is required to evaluate the costs of proposed regulations in order to adhere to various aspects of federal law and procedure regarding rulemaking. ATF has failed to adequately consider possible costs associated with the proposed rule making. The following review identifies areas for additional study and justification to ensure compliance with the Small Business Regularory Enforcement Fairness Act of 1996 and the Unfunded Mandates Reform Act of 1995. NUMBER OF RESPONSIBLE PERSONS PER ENTITY Section IV.A.2 states: “ATF estimates that each legal entity has an average of two responsible persons, an estimate that is based on ATF's review of 39 recent randomly selected paper (hardcopy) applications for corporations, LLCs, and trusts. ATF welcomes comments from the industry and other members of the public regarding the accuracy of its assumptions and estimates. ATF has not substantiated a reasonable estimate for the number of reasonable persons per entity. This is extremely significant as almost all other costs in the proposed rulemaking are derived from this figure. In Table A, ATF states that 40,700 legal entities filed applications in CY 2012. In order to generate a sample with a 5% confidence interval to 99% certainty, ATF would need to sample 655 legal entities. ATF’s survey of 39 randomly selected applications has a margin of error of around +/- 20% and is far too small to draw any conclusions on. ATF should sample at least 655 legal entities. Additionally, ATF has not attempted to determine how many legal entities add responsible persons after filing initial hard copy paperwork. For example, many corporations likely establish the corporate ownership with one or two owner/operators or managers, and then add officers as the enterprise expands. Likewise, many trusts established by families likely add responsible persons as the family grows in size over time. By examining only CY12 hardcopy submissions, ATF has introduced significant sample bias and again skewed their estimate of the size of a typical legal entity, which as described above has significant effects for all derived expenses. AVERAGE HOURLY COMPENSATION ATF used a compensation of $30.80 per hour based on average salary data. However, firearm owners in general and NFA owners in specific may have different salaries from the American population in general. ATF should justify the assumptions used in its salary estimates, which are especially critical as most costs are derived from this figure. For example, the National Shooting Sports Foundation found that the majority of Modern Sporting Rifle (AR-15 pattern) owners have an income exceeding $75,001 per year, and a quarter of owners have annual salaries exceeding $110,000 per year. This equates to hourly wages significantly in excess of ATF’s calculations. The survey is available online at http://www.nssf.org/msr/PDF/NSSF_MSR_Report2010.pdf. A 2010 Gallup exit poll found that gun owning voters had educational attainment rates significantly above the average population. 33% were college graduates, and 32% reported post-graduate study. In contrast, only about 30% of Americans are college graduates and only 11% have a postgraduate degree. Educational attainment is often correlated with income. ATF should justify its use of an average salary of $30.80 per hour, or utilize salary figures which reflect the majority of NFA owners. An industry group such as the NSSF should be able to assist in providing such data. AVERAGE HOURLY COMPENSATION ATF used a compensation of $30.80 per hour based on average salary data. However, firearm owners in general and NFA owners in specific may have different salaries from the American population in general. ATF should justify the assumptions used in its salary estimates, which are especially critical as most costs are derived from this figure. COST OF DOCUMENTS TO ESTABLISH EXISTENCE OF LEGAL ENTITY ATF used a sample of 50 applications to determine that the average legal entity application consists of 15 pages. As discussed above, a statistically significant sample would consist of 655 legal entities. ATF should sample a relevant number of entities to justify its estimate of 15 pages for copying expenses, or explain why this calculation should be based off of an arbitrary and statistically irrelevant sample. COST OF FINGERPRINTS ATF assesses that the cost of fingerprints is based on one hour of time. In many areas, only law enforcement provides fingerprinting services on ATF-approved hard copy FBI forms. This service is often only provided during business hours. Having fingerprints taken often requires the responsible person to take an entire day or at least half day off of work. For example, in my locality, fingerprints are only done for the public during a few hours each week during business hours. ATF should increase the time estimate from 60 minutes to four hours to reflect the reality that many applicants will need to take at least a half day off of work to obtain fingerprints in the ATF approved manner, or justify why an arbitrary estimate of 60 minutes was selected. Alternatively, ATF could consider allowing fingerprints to be submitted in an alternative manner, or utilize other proof of identity such as a social security number, concealed weapons permit, or other documentation. COST TO STATE AND LOCAL AGENCIES ATF estimated the time to review applications as 30 minutes. ATF has provided no justification to support this estimate. ATF should sample a statistically significant sample of Chief Law Enforcement Officers to determine actual review times. Some states such as Alaska have required CLEOs to sign off on these applications under penalty of law. CLEOs must therefore dedicate time and resources to fulfill these requirements. This represents a significant unfunded mandate on state and local governments. COSTS FOR A LEGAL ENTITY TO OBTAIN CLEO CERTIFICATE ATF estimates that the time needed for a responsible person to procure a CLEO certificate is 100 minutes. ATF has provided no justification of substantiation for this cost. ATF should sample a statistically relevant number of NFA item owners and determine the actual time to obtain CLEO signoff. Additionally, ATF should consider additional costs associated with the CLEO certificate beyond the applicant’s time. Some CLEOs impose arbitrary requirements to obtain the certificate such as acquisition of an FFL03 C&R license, Concealed Weapons Permit, and so on. Other CLEOs will not sign off for persons who are not personally known to them and their department, and costs to obtain the certificate may include attendance at police fundraisers, volunteer service with the department, and so on. Finally, a significant number of CLEOs are openly hostile to the idea of any citizen ownership of firearms, much less NFA items. The costs associated with CLEO sign off in these jurisdictions may be significant and include contributions to political campaigns, legal fees to retain an attorney, and so on. ADDITIONAL COSTS ATF has not evaluated the cost of this regulation on businesses or federal firearms licensees. The predictable impact of the rulemaking is to reduce sales of NFA items due to additional restrictions. This will impact federal firearms licensees and manufacturers. It will also likely impact the secondary market for resale of these items. ATF should address the probable impact of sales reduction to lawful citizens, and the effect on the secondary market. BENEFITS OF BACKGROUND CHECKS FOR RESPONSIBLE PERSONS ATF has failed to articulate any significant benefits to this policy. ATF highlighted two applications in which trustees were convicted felons. This transfer was not completed. ATF has provided zero evidence of NFA items acquired using legal entities by prohibited persons used in actual crimes. ATF has also failed to conduct any balance of the proposed costs with benefits. Even using ATF’s estimates of the cost of the regulation, which I feel are low and unsubstantiated, the cost of the rule making is expected to be in excess of $15 million per year. A 2010 Iowa State survey found that the average aggravated assaults costs $145,379 in damages and a murder is approximately $17 million. While every life is precious, and violent crime is a moral blight, a rulemaking should objectively compare costs and benefits. ATF has not presented evidence that any violent crimes, much less one as serious as murder, have occurred using NFA items obtained by a legal entity which would be prevented by the proposed rulemaking. The costs of the proposed rulemaking significantly exceed those of the probable benefits. ATF should provide additional substantiation of the probable benefits which can be expected by imposing the burdens of this rulemaking. Good point. Pick it apart and show how it's fiscally irresponsible. Keep this thing rolling guys. |
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Posted: 9/24/2013 10:08:17 PM EDT
[#22]
Quote HistoryQuoted: Congrats. I still got two suppressor stamps due that were sent in mid-January. Quote HistoryQuoted: Quoted: I just got a SBR form 1 (on a trust) back after 7 months. Congrats. I still got two suppressor stamps due that were sent in mid-January. I'm very bashful, and would never post a photo...oh wait!  This is not the final config, I'll eventually add a retro style telestock (already have), and a n A1 (no assist) upper. 
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Posted: 9/24/2013 10:10:47 PM EDT
[#23]
hit
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Posted: 9/24/2013 10:16:04 PM EDT
[#24]
Quote HistoryQuoted: yeah, telling them to GTH is definitely going to help our cause. Quote HistoryQuoted: Quoted: Snip yeah, telling them to GTH is definitely going to help our cause. |
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Posted: 9/24/2013 10:32:41 PM EDT
[#25]
done
I am 5 months into my third item form my trust |
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Posted: 9/24/2013 11:00:09 PM EDT
[#26]
for whatever a Canuck's opinion is worth, I hit it
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Posted: 9/24/2013 11:07:54 PM EDT
[#27]
Another "reinterpretation"........that's bullshit!
Only Congress has the Constitutionally delegated powers to propose and pass laws. Some anti-gun communist bureaucrat just making changes on a whim is bullshit. |
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Posted: 9/24/2013 11:29:31 PM EDT
[#28]
Quote HistoryQuoted:
Meh. They're going to do what they want to do regardless of how many comments or letters are sent their way. Colorado should have made this obvious to anyone paying attention. |
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Posted: 9/24/2013 11:41:54 PM EDT
[#29]
What about LLCs?
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Posted: 9/24/2013 11:53:01 PM EDT
[#30]
Quote HistoryQuoted:
A short and to the point bit of text: The CLEO certification is an archaic remnant of a bygone period where electronic records were unavailable to people running background checks. It does not provide any benefit to the background checking process, and is a burden both on the CLEO, and the applicant. Because it's not mandatory for the CLEO to sign your certification, yet you need it to be approved by the ATF, it has become a vehicle for nepotism and political favor. The CLEO certification should be dropped for all individuals and/or entities, and the ATF should go forward with only a background check on the responsible party. Sound logic and reason. The BATFags don't want any of that. |
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Posted: 9/25/2013 7:16:32 AM EDT
[#31]
Quote HistoryQuoted:
What about LLCs? The proposal applies to trusts, corporations, LLCs, and any other legal entity. |
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Posted: 9/25/2013 7:34:12 AM EDT
[#32]
done
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Posted: 9/25/2013 8:44:25 AM EDT
[#33]
Quote HistoryQuoted:
done No, we aren't done. The deadline for submitting comments is December 9th. Call every pro 2A person you know, email them, send them a Facebook message... put the word out to oppose this abomination! |
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Posted: 9/25/2013 9:12:48 AM EDT
[#34]
I have a feeling gun owners don't give a damn about this issue. Kinda like how fudds don't care about ARs.
Cant even get a tack in GD  Colorado got one.
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Posted: 9/25/2013 9:42:53 AM EDT
[#35]
hit
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Posted: 9/25/2013 10:08:17 AM EDT
[#36]
Quote HistoryQuoted:
I have a feeling gun owners don't give a damn about this issue. Kinda like how fudds don't care about ARs. Cant even get a tack in GD Colorado got one.If you keep sharing your thoughts and ideas, we will shed more light on this. Hope fully the moderators will take notice and pin it. Opposing these new regulations should be a priority for everyone on this forum. This is not about just NFA weapons; this is about gun rights at large. This is about everyone’s Second Amendment rights. The anti’s see this as a battle they have to win one inch at a time. They are patient, well organized, and resilient. I say don’t give them a single inch. Once you give up your rights, they’re gone. You don’t get them back. AR15.com Moderators, please pin this! |
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Posted: 9/25/2013 10:15:27 AM EDT
[#37]
This needs to be tacked, and the fight needs to be taken to congressmen.
Writing your senators and representatives WILL increase the pressure on the ATF. This is a tough fight. |
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Posted: 9/25/2013 10:27:46 AM EDT
[#38]
Cut and paste, boys.
Extending the CLEO requirement to fictitious entities is unnecessary and anachronistic. The advent of the NICS system and instant background checks makes a CLEO's signature unnecessary and overly burdensome. Much more importantly, though, the CLEO signature requirement constitutes a de-facto ban on the transfer of these perfectly legal weapons as many CLEOs will not sign off on the transfer either due to politics or ignorance about what they are being asked to do.
In my jurisdiction this will be a ban on the transfer or purchase of NFA items. I will be unable to purchase a suppressor to protect my and my children's hearing when shooting. Multiple studies have conclusively demonstrated that earmuffs, even when used in conjunction with earplugs, do not adequately protect against hearing loss for most calibers of weapons. This regulation will prevent law-abiding citizens from obtaining the best method for protecting their hearing. And to what end? The number of lawfully-purchased NFA items used in crime is abysmally low. Extending the CLEO requirement will do nothing but make these items more difficult, if not impossible, to obtain, while doing nothing to reduce gun violence. If background checks are to be required for fictitious entities, that is one thing. But extending the CELO requirement to fictitious entities will operate as a de facto ban and have a clearly detrimental effect on my ability to protect my hearing, and the hearing of those around me. |
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Posted: 9/25/2013 10:27:59 AM EDT
[#39]
What about transfers to Corporations?
Just wondering if that could be a work around if this is implemented. |
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Posted: 9/25/2013 10:29:16 AM EDT
[#40]
Quote HistoryQuoted:
What about transfers to Corporations? Just wondering if that could be a work around if this is implemented. All fictitious entities. Trust, corporation, LLC, LLP, LP, you name it. CLEO signature required for all. |
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Posted: 9/25/2013 10:31:53 AM EDT
[#41]
Quote HistoryQuoted:
All fictitious entities. Trust, corporation, LLC, LLP, LP, you name it. CLEO signature required for all. Quote HistoryQuoted:
Quoted:
What about transfers to Corporations? Just wondering if that could be a work around if this is implemented. All fictitious entities. Trust, corporation, LLC, LLP, LP, you name it. CLEO signature required for all. It's buried somewhere in the language of the proposal, but it's there. If this thing gets implemented, say goodbye to anything NFA |
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Posted: 9/25/2013 10:49:46 AM EDT
[#42]
Quote HistoryQuoted:
Cut and paste, boys. Quote HistoryQuoted:
Cut and paste, boys. Extending the CLEO requirement to fictitious entities is unnecessary and anachronistic. The advent of the NICS system and instant background checks makes a CLEO's signature unnecessary and overly burdensome. Much more importantly, though, the CLEO signature requirement constitutes a de-facto ban on the transfer of these perfectly legal weapons as many CLEOs will not sign off on the transfer either due to politics or ignorance about what they are being asked to do.
In my jurisdiction this will be a ban on the transfer or purchase of NFA items. I will be unable to purchase a suppressor to protect my and my children's hearing when shooting. Multiple studies have conclusively demonstrated that earmuffs, even when used in conjunction with earplugs, do not adequately protect against hearing loss for most calibers of weapons. This regulation will prevent law-abiding citizens from obtaining the best method for protecting their hearing. And to what end? The number of lawfully-purchased NFA items used in crime is abysmally low. Extending the CLEO requirement will do nothing but make these items more difficult, if not impossible, to obtain, while doing nothing to reduce gun violence. If background checks are to be required for fictitious entities, that is one thing. But extending the CELO requirement to fictitious entities will operate as a de facto ban and have a clearly detrimental effect on my ability to protect my hearing, and the hearing of those around me. You raise some good points here. Keep the discussion going ladies & gentlemen, we have to draw as much attention to this as we can. |
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Posted: 9/25/2013 11:17:41 AM EDT
[#43]
Quote HistoryQuoted:
+1 Quote HistoryQuoted:
Quoted:
Any chance there's a moderator who could pin this? At least pin it until December 9? +1 We have to keep this thread alive. Does anyone know how to get the moderators to tack it up? |
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Posted: 9/25/2013 11:30:26 AM EDT
[#44]
Hit
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Posted: 9/25/2013 11:37:20 AM EDT
[#45]
Submitted my comments
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Posted: 9/25/2013 11:40:37 AM EDT
[#46]
hit
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Posted: 9/25/2013 11:57:23 AM EDT
[#47]
Hit it with extreme prejudice.
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Posted: 9/25/2013 12:00:10 PM EDT
[#48]
Quote HistoryQuoted:
It's buried somewhere in the language of the proposal, but it's there. If this thing gets implemented, say goodbye to anything NFA Quote HistoryQuoted:
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What about transfers to Corporations? Just wondering if that could be a work around if this is implemented. All fictitious entities. Trust, corporation, LLC, LLP, LP, you name it. CLEO signature required for all. It's buried somewhere in the language of the proposal, but it's there. If this thing gets implemented, say goodbye to anything NFA Wonder if there will be an exemption for movie industry groups. They are the biggest owners of NFA weapons in the nation. They ought to be going nuts over this new proposal. |
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Posted: 9/25/2013 12:10:48 PM EDT
[#49]
Quote HistoryQuoted:
It's buried somewhere in the language of the proposal, but it's there. If this thing gets implemented, say goodbye to anything NFA Quote HistoryQuoted:
Quoted:
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What about transfers to Corporations? Just wondering if that could be a work around if this is implemented. All fictitious entities. Trust, corporation, LLC, LLP, LP, you name it. CLEO signature required for all. It's buried somewhere in the language of the proposal, but it's there. If this thing gets implemented, say goodbye to anything NFA How do you figure? It will be more difficult but not impossible...unless I missed something?? |
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Posted: 9/25/2013 12:13:40 PM EDT
[#50]
if this was 1774 we would cut our barrels down and say FU come and take them..
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