https://www.atf.gov/rules-and-regulations/definition-frame-or-receiver

So sad.

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Can someone please explain the implications of this?

Requires you (All FFLs to include 03) to keep records indefinitely.  How to engrave/mark Privately Made Firearms that FFLs acquire.  Adds Gunsmith 01 FFL to engrave PMFs.  Changes Receiver/Frame to 80% Firearm Parts kits, ie add SN and go thru FFL, taxes, NICS, etc.  Defines what part of a split receiver receives the SN (AR15 lower example), striker fired guns.  Requires FFLs to include their private collection of PMFs to be SN and added to A&D.  Just loads of shit for us.

CD

I took a few minutes to scan the proposed rule and came away with a few thoughts.

First, for some reason the rule seems to be obsessivley focused on parts kits that contain an "incomplete" receiver that can "readily be" completed by an "unskilled" person.
My guess is that obsession derives from some combination of typically emotion-driven liberal politics with the legitimate concerns of law enforcement.

The mindset seems to be all about what the ATF calls "firearms kits" which could be "easily obtained" by criminals, etc. and used to manufacture their own untraceable "ghost" guns.
This ignores the fact that it is far easier for criminals to steal, or purchase stolen, firearms than it is to invest in the time and tools to make their own receivers.
They also seem to be overly concerned with kits that include jigs, fixtures, tools, etc. that make it easy for the average person to complete the receiver.

I also notice that while the rule is focused on kits, it really doesn't do much to address parts/kits purchased without an  80% receiver, or vice-versa.
From what I read, it would continue to be legal, simple and easy for a person to buy all the components (i.e. 80% receiver, parts kit and tools) separately.

So while that's something to be worried about in terms of gradual infringement, it doesn't seem to change much as a practical matter.

Second issue kind of dovetails with the first because it's about making guns traceable. While Privately Made Firearms (new ATF classification: PMFs) can still be made by unlicensed individuals, once they enter the marketplace via an FFL that FFL must apply a serial number to that firearm. It's nice that the ATF does hold FFLs harmless for any problems such guns might have regarding function or safety, it's another burden for FFLs to deal with. I wonder, if a person makes a hot rod, dune buggy or rock crawler, does a car dealer have to assign it a VIN? That would make an interesting analogy since they are both required to be licensed to do business as dealers.

However, a privately made firearm would not be required to have a serial number applied by the person making it.
(NOTE: The rule adds a clear distinction between "manufacturing" and "making" firearms: the former is for commercial manufacturers and the latter if for individuals making personal firearms.

Third is the broadened definition of "receiver" as regards firearms that don't have all of the fire control parts contained within one enclosed piece.
The first thing that stands out is that the requirement to serialize both/all pieces of a firearm's "receiver" would only apply to new designs.
Virtually all current designs, from the 1911 and Thompson SMG to more modern designs would be excluded from the requirement.
Notably, the AR-15 and Sig Sauer 320 series are specifically excluded. The latter is significant because the ATF recognizes that the fire control module is essentially self-contained.
Again, I think this is creeping infringement because it opens the door for the ATF to make things up as it goes along, or a liberal president fundamentally changing intent or scope via executive order.

Fourth, and possibly the most scary long-term is the proposed changes to record-keeping requirements.
It would change the required time for FFLs to keep records from 20 years to indefinitely.
It would allow FFLs to use an off-premise "warehouse" to keep those records, or it could keep them in electronic format.
That last feature, which purports to make things easier for FFLs to keep those records forever, would also give the government an easy way to instantly search or acquire an FFL's entire transaction record back to the beginning of time. It would only take a minor rule change to require those electronic records to be uploaded to the ATF periodically, or even transition to some kind of server-based storage - on government servers, of course. That might allow the government to establish a de-facto gun/owner registration database while maintaining plausible deniability that they weren't doing so.

So that's my take-away. Not as bad as might have been feared, but it's just another "reasonable reform" to "help law enforcement do its job," another little step down the path towards gutting our 2nd Amendment rights.

I tried looking up how long the comment review period is.. but no luck. If it is 30 days then we should be close to some news right?