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5/2/2026 3:51:41 PM EDT
[#1]
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Quoted:
The big problem with non-OTC firearm sales is that 18 USC 922(c)(3) requires that the FFL send the transferee's CLEO a notification of the purchase and then wait seven days before shipping the gun, so in most instances it'll still be simpler to just go pick it up in person.  It's one thing to add a week onto a purchase timeline for an NFA firearm that already takes a month-plus, but it's something else to add a week onto the purchase time for a non-NFA firearm that otherwise could be done in minutes.
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Can someone explain like I'm 5 years old what a "non over the counter firearm sale" actually is and what this change means to the average joe?


I am good with the rest, but my google-fu is failing me for a clear and concise answer to the non over the counter definition...?

Face to face private sale?


No, this applies to FFL's. You fill out a 4473 online and a business in a town 3 hours away in the same state can ship you a firearm same as if you had walked into the store.
The big problem with non-OTC firearm sales is that 18 USC 922(c)(3) requires that the FFL send the transferee's CLEO a notification of the purchase and then wait seven days before shipping the gun, so in most instances it'll still be simpler to just go pick it up in person.  It's one thing to add a week onto a purchase timeline for an NFA firearm that already takes a month-plus, but it's something else to add a week onto the purchase time for a non-NFA firearm that otherwise could be done in minutes.

In communist enclaves with a waiting period (like Kolorado) the non-OTC could be a big win. Driving 3 hours each way to get your new gun is one thing, but doing that TWICE (once to buy it, then again 3+ days later to pick it up) might make the few extra days a win. Even in town, I’d likely take “to-my-door” service - and if PSA had this akin to what CA does now for NFA stuff (with local FFL partners/locations), it would be amazing!
5/2/2026 5:29:46 PM EDT
[#2]
Quote History
Quoted:

The big problem with non-OTC firearm sales is that 18 USC 922(c)(3) requires that the FFL send the transferee's CLEO a notification of the purchase and then wait seven days before shipping the gun, so in most instances it'll still be simpler to just go pick it up in person.  It's one thing to add a week onto a purchase timeline for an NFA firearm that already takes a month-plus, but it's something else to add a week onto the purchase time for a non-NFA firearm that otherwise could be done in minutes.
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given gas prices, it would still be way easier than trying to drive from Dallas to Houston to pick up something that you spotted on sale.
5/2/2026 5:39:50 PM EDT
[#3]
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Sour grapes guy bitching that ATF won’t say a SBR isn’t an SBR if you use a brace instead of a stock.

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Sour grapes guy bitching that ATF won’t say a SBR isn’t an SBR if you use a brace instead of a stock.




Most gunshops in my area stock braced pistols and have for the last several years while those multiple cases were litigated. Right in plain view even...(GASP!!!) I know for a fact that severals of them have had their annual-semi-annual inspections by the local ATF Compliance folks. NONE of them have been charged, harassed or any other thing because they have these displayed for sale.
5/2/2026 6:00:10 PM EDT
[#4]
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Will PSA do this?
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No, this applies to FFL's. You fill out a 4473 online and a business in a town 3 hours away in the same state can ship you a firearm same as if you had walked into the store.



Thats actually pretty awesome.
Will PSA do this?


I think they are doimg it for supressors?
Its in partneship with Capital Armory though.
Way to go CA!

I bought 2 through CA shipped to my door.  Went without an issue although I will always look to see if my local place can get it.  Its faster.
5/2/2026 6:22:24 PM EDT
[#5]
They need to kill the open bolt semi auto ban.
5/2/2026 8:50:23 PM EDT
[#6]
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Face to face private sale?
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Can someone explain like I'm 5 years old what a "non over the counter firearm sale" actually is and what this change means to the average joe?


I am good with the rest, but my google-fu is failing me for a clear and concise answer to the non over the counter definition...?

Face to face private sale?


Nope. Online 4473 and FFL mails it to your house. Only works if the FFL is in your state and there’s no state laws preventing such sales.

You can buy a car without ever going to the dealership. You can buy a house without ever seeing it in person. There is no reason you should have to go to the store to buy a gun.
5/2/2026 8:55:17 PM EDT
[#7]
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Most gunshops in my area stock braced pistols and have for the last several years while those multiple cases were litigated. Right in plain view even...(GASP!!!) I know for a fact that severals of them have had their annual-semi-annual inspections by the local ATF Compliance folks. NONE of them have been charged, harassed or any other thing because they have these displayed for sale.
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Sour grapes guy bitching that ATF won’t say a SBR isn’t an SBR if you use a brace instead of a stock.




Most gunshops in my area stock braced pistols and have for the last several years while those multiple cases were litigated. Right in plain view even...(GASP!!!) I know for a fact that severals of them have had their annual-semi-annual inspections by the local ATF Compliance folks. NONE of them have been charged, harassed or any other thing because they have these displayed for sale.


Braced pistols are fine. Using a brace on a SBR doesn’t make it a pistol. Totally of the circumstances including intent and manner in which the firearm is used determines the difference.
5/2/2026 9:30:04 PM EDT
[#8]
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Braced pistols are fine. Using a brace on a SBR doesn’t make it a pistol. Totally of the circumstances including intent and manner in which the firearm is used determines the difference.
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But muh ADA!
5/2/2026 9:36:30 PM EDT
[#9]
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Braced pistols are fine. Using a brace on a SBR doesn’t make it a pistol. Totally of the circumstances including intent and manner in which the firearm is used determines the difference.
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Sour grapes guy bitching that ATF won’t say a SBR isn’t an SBR if you use a brace instead of a stock.




Most gunshops in my area stock braced pistols and have for the last several years while those multiple cases were litigated. Right in plain view even...(GASP!!!) I know for a fact that severals of them have had their annual-semi-annual inspections by the local ATF Compliance folks. NONE of them have been charged, harassed or any other thing because they have these displayed for sale.


Braced pistols are fine. Using a brace on a SBR doesn’t make it a pistol. Totally of the circumstances including intent and manner in which the firearm is used determines the difference.

Misuse doesn't change a pistol into a rifle any more than driving a car into a lake changes it into a boat.
5/2/2026 10:03:26 PM EDT
[#10]
Quote History
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No, this applies to FFL's. You fill out a 4473 online and a business in a town 3 hours away in the same state can ship you a firearm same as if you had walked into the store.
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Can someone explain like I'm 5 years old what a "non over the counter firearm sale" actually is and what this change means to the average joe?


I am good with the rest, but my google-fu is failing me for a clear and concise answer to the non over the counter definition...?

Face to face private sale?


No, this applies to FFL's. You fill out a 4473 online and a business in a town 3 hours away in the same state can ship you a firearm same as if you had walked into the store.


Clear answer, thank you.
I am sure all the semi-retarded people (like me), on the forum thank you as well.
5/2/2026 10:18:32 PM EDT
[#11]
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Misuse doesn't change a pistol into a rifle any more than driving a car into a lake changes it into a boat.
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Sour grapes guy bitching that ATF won’t say a SBR isn’t an SBR if you use a brace instead of a stock.




Most gunshops in my area stock braced pistols and have for the last several years while those multiple cases were litigated. Right in plain view even...(GASP!!!) I know for a fact that severals of them have had their annual-semi-annual inspections by the local ATF Compliance folks. NONE of them have been charged, harassed or any other thing because they have these displayed for sale.


Braced pistols are fine. Using a brace on a SBR doesn’t make it a pistol. Totally of the circumstances including intent and manner in which the firearm is used determines the difference.

Misuse doesn't change a pistol into a rifle any more than driving a car into a lake changes it into a boat.

True
5/2/2026 11:48:27 PM EDT
[#12]
Quote History


Thank you, kind sir.   Looks pretty good.
5/3/2026 8:40:03 AM EDT
[#13]
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Misuse doesn't change a pistol into a rifle any more than driving a car into a lake changes it into a boat.
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Quoted:
Quoted:
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Sour grapes guy bitching that ATF won’t say a SBR isn’t an SBR if you use a brace instead of a stock.




Most gunshops in my area stock braced pistols and have for the last several years while those multiple cases were litigated. Right in plain view even...(GASP!!!) I know for a fact that severals of them have had their annual-semi-annual inspections by the local ATF Compliance folks. NONE of them have been charged, harassed or any other thing because they have these displayed for sale.


Braced pistols are fine. Using a brace on a SBR doesn’t make it a pistol. Totally of the circumstances including intent and manner in which the firearm is used determines the difference.

Misuse doesn't change a pistol into a rifle any more than driving a car into a lake changes it into a boat.


“The manner in which it is used defines the tool” is long established in criminal courts.

Sometimes a table leg is just a table leg. Sometimes a table leg is a billy club.
5/3/2026 10:53:05 AM EDT
[#14]
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“The manner in which it is used defines the tool” is long established in criminal courts.

Sometimes a table leg is just a table leg. Sometimes a table leg is a billy club.
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Sour grapes guy bitching that ATF won’t say a SBR isn’t an SBR if you use a brace instead of a stock.




Most gunshops in my area stock braced pistols and have for the last several years while those multiple cases were litigated. Right in plain view even...(GASP!!!) I know for a fact that severals of them have had their annual-semi-annual inspections by the local ATF Compliance folks. NONE of them have been charged, harassed or any other thing because they have these displayed for sale.


Braced pistols are fine. Using a brace on a SBR doesn’t make it a pistol. Totally of the circumstances including intent and manner in which the firearm is used determines the difference.

Misuse doesn't change a pistol into a rifle any more than driving a car into a lake changes it into a boat.


“The manner in which it is used defines the tool” is long established in criminal courts.

Sometimes a table leg is just a table leg. Sometimes a table leg is a billy club.

Which leads to the question, when does an object become a weapon?

It seems many laws use firearm and weapon somewhat interchangeably and they are not.

SPORTING use/purpose anybody...
5/3/2026 10:59:00 AM EDT
[#15]
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Man! This is a step in the right direction!

Sweet Jesus, its almost like the government possibly sees a war on US soil, and they want people to feel a little better about owning and possessing guns that they want.

No NFA fees, you don't have to engrave/ gouge up you prized firearms. Oh and you can carry them to other states freely on a whim for up to a whole year with out the hassle and waiting on approval.

I for one will be loving this. Looks like most of the reasons to stick to braces is gone!



ETA: Thanks Donald J Trump!
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"Drumpf hasn't done anything for gun owners..."

5/3/2026 2:31:35 PM EDT
[#16]
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"Drumpf hasn't done anything for gun owners..."

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Quoted:
Man! This is a step in the right direction!

Sweet Jesus, its almost like the government possibly sees a war on US soil, and they want people to feel a little better about owning and possessing guns that they want.

No NFA fees, you don't have to engrave/ gouge up you prized firearms. Oh and you can carry them to other states freely on a whim for up to a whole year with out the hassle and waiting on approval.

I for one will be loving this. Looks like most of the reasons to stick to braces is gone!



ETA: Thanks Donald J Trump!

"Drumpf hasn't done anything for gun owners..."



Trump definitely could’ve been better on guns his first term, and was likely listening to shitty GOPe advisors.

While he’s still not perfect this term, any gun owner still “upset” about Trump being in the White House in 2026 is suffering from terminal stage TDS.

These sorts of reforms would’ve been unheard of under any previous administration regardless of party.
5/3/2026 2:32:47 PM EDT
[#17]
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Trump definitely could’ve been better on guns his first term, and was likely listening to shitty GOPe advisors.

While he’s still not perfect this term, any gun owner still “upset” about Trump being in the White House in 2026 is suffering from terminal stage TDS.

These sorts of reforms would’ve been unheard of under any previous administration regardless of party.
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But bro…bump stocks.
5/3/2026 2:39:30 PM EDT
[#18]
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But bro…bump stocks.
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That was pure politics.

If someone used an FRT to conduct a similar high profile mass killing you would probably see similar action today, but with the same long term result.

There is tons of pressure for politicians to “do something” after an event like that.

While I won’t defend it, Trumps action on bump stocks was probably the best way of “doing something” without actually doing something in the long run.
5/3/2026 2:41:50 PM EDT
[#19]
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That was pure politics.

If someone used an FRT to conduct a similar high profile mass killing you would probably see similar action today, but with the same long term result.

There is tons of pressure for politicians to “do something” after an event like that.

While I won’t defend it, Trumps action on bump stocks was probably the best way of “doing something” without actually doing something in the long run.
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But bro…bump stocks.


That was pure politics.

If someone used an FRT to conduct a similar high profile mass killing you would probably see similar action today, but with the same long term result.

There is tons of pressure for politicians to “do something” after an event like that.

While I won’t defend it, Trumps action on bump stocks was probably the best way of “doing something” without actually doing something in the long run.

I was just kidding. For all his faults (of which there are many) I’ve never seen a president in my lifetime this good. Domestic, foreign and now 2A. I’m pretty happy.
5/3/2026 2:45:52 PM EDT
[#20]
Quote History
Quoted:


That was pure politics.

If someone used an FRT to conduct a similar high profile mass killing you would probably see similar action today, but with the same long term result.

There is tons of pressure for politicians to “do something” after an event like that.

While I won’t defend it, Trumps action on bump stocks was probably the best way of “doing something” without actually doing something in the long run.
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Quoted:
Quoted:

But bro…bump stocks.


That was pure politics.

If someone used an FRT to conduct a similar high profile mass killing you would probably see similar action today, but with the same long term result.

There is tons of pressure for politicians to “do something” after an event like that.

While I won’t defend it, Trumps action on bump stocks was probably the best way of “doing something” without actually doing something in the long run.


It only amounted to nothing in the long run because of a tremendous legal effort to thwart it.  An effort that was FAR from a sure thing.  Several circuit courts upheld it before one finally overturned it.
5/3/2026 2:47:00 PM EDT
[#21]
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I was just kidding. For all his faults (of which there are many) I’ve never seen a president in my lifetime this good. Domestic, foreign and now 2A. I’m pretty happy.
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I know you were.

I was just pointing out that anyone shocked by his actions on bump stocks last administration had unrealistic expectations.

And yeah, I’d agree. He’s kicking ass. Perfect? Nah, but literally light years ahead of any president in modern history. The only person that comes remotely close is Reagan.

I couldn’t imagine calling oneself a conservative, having the context of HW Bush, GW Bush, McCain and Romney as presidential nominees over the past nearly 40 years, and still being upset about Trump.
5/3/2026 2:50:31 PM EDT
[#22]
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It only amounted to nothing in the long run because of a tremendous legal effort to thwart it.  An effort that was FAR from a sure thing.  Several circuit courts upheld it before one finally overturned it.
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It only amounted to nothing in the long run because of a tremendous legal effort to thwart it.  An effort that was FAR from a sure thing.  Several circuit courts upheld it before one finally overturned it.

Quoted:


It only amounted to nothing in the long run because of a tremendous legal effort to thwart it.  An effort that was FAR from a sure thing.  Several circuit courts upheld it before one finally overturned it.


The bump stock ban likely quelled a lot of the immense pressure for new legislation.

I’ll take a shitty rule change over shitty legislation any day of the week and twice on Sunday.

ETA I’m not saying I agreed with it or was happy about it, but I can understand why it happened politically.
5/3/2026 2:52:43 PM EDT
[#23]
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The bump stock ban likely quelled a lot of the immense pressure for new legislation.

I’ll take a shitty rule change over shitty legislation any day of the week and twice on Sunday.
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It only amounted to nothing in the long run because of a tremendous legal effort to thwart it.  An effort that was FAR from a sure thing.  Several circuit courts upheld it before one finally overturned it.

Quoted:


It only amounted to nothing in the long run because of a tremendous legal effort to thwart it.  An effort that was FAR from a sure thing.  Several circuit courts upheld it before one finally overturned it.


The bump stock ban likely quelled a lot of the immense pressure for new legislation.

I’ll take a shitty rule change over shitty legislation any day of the week and twice on Sunday.


Completely unfalsifiable assertion.

And anyways, what was the threat?  Trump was going to sign worse actual legislation than his own imperial decree?   You dont have to do gymnastics to excuse his de facto gun control.  It was a shit move, period.
5/3/2026 2:54:03 PM EDT
[#24]
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Completely unfalsifiable assertion.

And anyways, what was the threat?  Trump was going to sign worse actual legislation than his own imperial decree?   You dont have to do gymnastics to excuse his de facto gun control.  It was a shit move, period.
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Granted. I’ll give you that. How about ATF changes today? Shit move or positive?
5/3/2026 2:58:06 PM EDT
[#25]
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Granted. I’ll give you that. How about ATF changes today? Shit move or positive?
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Completely unfalsifiable assertion.

And anyways, what was the threat?  Trump was going to sign worse actual legislation than his own imperial decree?   You dont have to do gymnastics to excuse his de facto gun control.  It was a shit move, period.

Granted. I’ll give you that. How about ATF changes today? Shit move or positive?


I haven't read through them all.  So far ranging from mildly positive to meh.  Im just relieved he didn't sneak new BS in.
5/3/2026 3:00:06 PM EDT
[#26]
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Completely unfalsifiable assertion.

And anyways, what was the threat?  Trump was going to sign worse actual legislation than his own imperial decree?   You dont have to do gymnastics to excuse his de facto gun control.  It was a shit move, period.
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Quoted:
Quoted:
Quoted:


It only amounted to nothing in the long run because of a tremendous legal effort to thwart it.  An effort that was FAR from a sure thing.  Several circuit courts upheld it before one finally overturned it.

Quoted:


It only amounted to nothing in the long run because of a tremendous legal effort to thwart it.  An effort that was FAR from a sure thing.  Several circuit courts upheld it before one finally overturned it.


The bump stock ban likely quelled a lot of the immense pressure for new legislation.

I’ll take a shitty rule change over shitty legislation any day of the week and twice on Sunday.


Completely unfalsifiable assertion.

And anyways, what was the threat?  Trump was going to sign worse actual legislation than his own imperial decree?   You dont have to do gymnastics to excuse his de facto gun control.  It was a shit move, period.


See my edit. I wasn’t happy about it, and I don’t think it should’ve happened, but politically I can understand why it happened.

I still blame GOPe advisors. Trump was still worried about winning a second term and those people probably told him he had to do “something” in the wake of Vegas.

Either way, it worked out for the best in the long run.
5/5/2026 12:30:41 PM EDT
[#28]
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Thanks for the heads up.

I'm happy to say my first guess on the engraving rule was wrong, and this does indeed appear to remove the requirement for all added maker's markings; including your name, city/state; when using an existing firearm with original manufacturer's markings present.
5/5/2026 12:50:50 PM EDT
[#29]
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How long before these new rules are effective?  Google says 30 days.
5/5/2026 1:01:37 PM EDT
[#30]
Quote History
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Thanks for the heads up.

I'm happy to say my first guess on the engraving rule was wrong, and this does indeed appear to remove the requirement for all added maker's markings; including your name, city/state; when using an existing firearm with original manufacturer's markings present.
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Quoted:
Thanks for the heads up.

I'm happy to say my first guess on the engraving rule was wrong, and this does indeed appear to remove the requirement for all added maker's markings; including your name, city/state; when using an existing firearm with original manufacturer's markings present.
I found this statement most interesting in the rule about markings (in regards to lack of additional markings and tracing)

Moreover, the number of NFA firearms, excluding machine gun conversion devices,
that are recovered from a crime scene is a very small subset of the overall firearms traced. In
FY25, for example, the total number of firearms traces was 654,879, and of those, 3,195
were coded as NFA firearms; specifically, 196 destructive devices, 1,512 machine guns
(excluding machine gun conversion devices), and 1,487 silencers. As a result, even if an
NFA firearm is made by adopting the existing markings and is recovered at a crime scene but
could not be traced using the original manufacturer markings, the number of such firearms
would be exceedingly small.



5/5/2026 1:04:09 PM EDT
[#31]
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How long before these new rules are effective?  Google says 30 days.
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How long before these new rules are effective?  Google says 30 days.


The comment period is 60 days, then they have to review the comments and publish a final rule.

DATES: Comments must be submitted in writing, and must be submitted on or before (or, if
mailed, must be postmarked on or before) [INSERT DATE 60 DAYS AFTER DATE OF
PUBLICATION IN THE FEDERAL REGISTER].
5/5/2026 1:17:00 PM EDT
[#32]
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Misuse doesn't change a pistol into a rifle any more than driving a car into a lake changes it into a boat.
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5/6/2026 8:25:15 PM EDT
[#33]
First one is published : https://www.federalregister.gov/documents/2026/05/06/2026-08912/removing-cleo-notification-under-the-national-firearms-act

Removing CLEO Notification Under the National Firearms Act

Published Document: 2026-08912 (91 FR 24471)

Department of Justice
Bureau of Alcohol, Tobacco, Firearms, and Explosives
27 CFR Part 479
[Docket No. ATF-2026-0004; ATF No. 2025R-15P]
RIN 1140-AA65
5/6/2026 8:33:40 PM EDT
[#34]
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First one is published : https://www.federalregister.gov/documents/2026/05/06/2026-08912/removing-cleo-notification-under-the-national-firearms-act

Removing CLEO Notification Under the National Firearms Act

Published Document: 2026-08912 (91 FR 24471)

Department of Justice
Bureau of Alcohol, Tobacco, Firearms, and Explosives
27 CFR Part 479
[Docket No. ATF-2026-0004; ATF No. 2025R-15P]
RIN 1140-AA65
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A bunch of them were officially published today.

https://www.federalregister.gov/documents/search?conditions%5Bagencies%5D%5B%5D=alcohol-tobacco-firearms-and-explosives-bureau&conditions%5Bsearch_type_id%5D=3&order=newest
5/7/2026 9:26:46 AM EDT
[#35]
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Quoted:
First one is published : https://www.federalregister.gov/documents/2026/05/06/2026-08912/removing-cleo-notification-under-the-national-firearms-act

Removing CLEO Notification Under the National Firearms Act

Published Document: 2026-08912 (91 FR 24471)

Department of Justice
Bureau of Alcohol, Tobacco, Firearms, and Explosives
27 CFR Part 479
[Docket No. ATF-2026-0004; ATF No. 2025R-15P]
RIN 1140-AA65
View Quote



Lol, I just dropped off my latest Form 1 application at the Sheriff's office yesterday. I am sure he glances at them and pitches them.
5/7/2026 5:34:06 PM EDT
[#36]
How much interest is there if I did the same for all these new proposals?  

I always hate the puke that goes up on youtube on these releases.  I'd rather have a concise report.  I've created one in AI for speed and accuracy.

Open to any way I can improve the report.  This is the first and an example.

My background: I had some good years following TX state laws and publishing here.  
https://www.ar15.com/forums/hometown/Open-Carry-2015-Session-84-Passes-Senate-SB-17-/8-578777/  
https://www.ar15.com/forums/hometown/Texas-Gun-Legislation-2013/8-503210/


Meet my AI team monitoring these new rules.

Document Summary

Rule: NPRM 2025R-15P, "Removing CLEO Notification Under the National Firearms Act" (RIN 1140-AA65, Docket ATF-2026-0004)

What it does: Eliminates the requirement that NFA applicants forward a copy of Form 1 (making), Form 4 (transfer), or Form 23 (responsible person questionnaire) to their local Chief Law Enforcement Officer. Removes 27 CFR 479.62(c) and 479.84(c).

Who's affected: Every individual or trust applying to make or transfer an NFA item   suppressors, SBRs, SBSs, AOWs, machine guns, destructive devices. Approximately 1.17M applications in 2024; projected to exceed 2M annually by 2034.

Historical context: Fourth step in a 12-year deregulatory progression. Pre-2014 required CLEO certification (signature). 2014-2016 made certification optional. 2016 replaced certification with notification (copy only, no signature, CLEO could object). This rule eliminates the touchpoint entirely.

ATF's stated rationale: CLEOs don't perform independent background checks on notifications, don't file objections, and generally discard the forms. ATF performs its own NICS check and state-law review. Notification serves no investigative function and imposes documented cost on applicants.

Cost-benefit: ATF estimates $11.4M annual savings, $115.8M over ten years (3% discount rate), based on 15 minutes per application   $26 leisure wage = $7 per applicant.Legal basis: Lomont v. O'Neill (DC Cir. 2002) upheld the original CLEO requirement as an implied regulatory power, not a statutory mandate. ATF can remove what it could create.Procedural status: Notice of Proposed Rulemaking. 60-day comment period closes early July 2026. Signed by Director Robert Cekada   his first signed rulemaking. Published in Federal Register May 6, 2026.

What it does NOT do: Does not affect the NFRTR central registry, fingerprint/photo requirements, approval waits, or any state-level NFA restrictions. Does not change the OBBBA $0 tax (separate rule, 45F).

The Regulatory Strike Team   Roster & Findings Log
Who's on the Team

The Architect   Former CRS analyst, regulatory drafting expert
  • Looking for: structural quality of rulemaking, completeness of factual record, alignment between operative text and stated purpose
The Litigator   Veteran 2A appellate attorney, post-Bruen APA specialist
  • Looking for: APA arbitrary-and-capricious exposure, durability under judicial review, Loper Bright implications
The Dealer   Former ATF IOI turned FFL compliance consultant
  • Looking for: operational impact on FFL inspection risk, customer-facing transaction friction, field-level implementation reality
The NFA Guru   NFA trust attorney and Class III dealer
  • Looking for: practical impact on suppressor/SBR owners, NFA process simplification, registry mechanics
The Privacy Sentinel   Digital rights attorney
  • Looking for: record retention, registry expansion, data architecture, FOPA implications
The Veteran (Movement Skeptic)   2A litigator with 30 years of pendulum experience
  • Looking for: durability across administrations, statute vs. SCOTUS vs. regulatory tier, reversal probability
The Compliance Cassandra   FFL defense attorney, former industry counsel

  • Looking for: risk migration to state/civil/alternative federal channels, new compliance traps inside rollbacks
Findings on Rule 15P (CLEO Notification Removal)

The Architect
Pros
  • Unusually frank agency record   explicitly states 2016 system "has not worked as intended"
  • Cost analysis uses defensible HHS leisure-wage methodology ($26/hr   0.25hr = $7/application)
  • $11.4M annual / $115.8M ten-year savings, modest but documented
  • Explicitly invites CLEO comments   procedural sophistication that strengthens any final rule
  • Statutory authority undisturbed; no preemption issues
Cons
  • Per-application time estimate (15 min) likely undercounts real burden by half
  • Doesn't address whether NFRTR retention itself should change

Bottom line: Textbook regulatory hygiene; one of the cleanest rules in the package

The Litigator
Pros
  • Lomont v. O'Neill (DC Cir. 2002) settled that CLEO requirement is implied power   ATF can remove what it could create
  • Complete factual record: CLEOs don't perform background checks, don't file objections, generally discard notices
  • Post-Loper Bright, courts won't defer but the merits are clean
  • Re-promulgation by future administration must overcome ATF's documented finding that notification didn't work
Cons
  • Lomont still authorizes the underlying implied power   future administration could re-promulgate with new factual findings
  • Loper Bright cuts both ways; helps the next administration's re-promulgation survive too

Bottom line: Minimal APA exposure; one of the most defensible rescissions in the package

The Dealer
Pros
  • Reduces customer abandonment in jurisdictions with hostile/political CLEOs
  • Multi-RP trusts dramatically simplified (was 1 mailing per RP per jurisdiction)
  • Removes a real friction point that loses sales for Class III dealers
  • No new dealer compliance burden

Cons
  • Doesn't affect dealer 4473/A&D obligations   upstream of dealer transaction
  • IOI inspection profile unchanged

Bottom line: Marginal but real revenue benefit for SOT dealers; no operational downside

The NFA Guru
Pros
  • Third leg of meaningful NFA simplification (with 13P spousal, 03P transport)
  • Real-world per-application savings likely 30-45 min, not just the $7 ATF estimates
  • Complements OBBBA $0 tax effective Jan 1, 2026
  • Eliminates jurisdictional politics from federal NFA process

Cons
  • Does nothing to NFRTR registry, fingerprints, photos, approval wait
  • Incremental, not transformative   the registry remains
  • Constitutional question on registry continues separately (Silencer Shop Foundation litigation)

Bottom line: Real win for individual NFA buyers; doesn't touch the structural questions

The Privacy Sentinel
Pros
  • Eliminates local-law-enforcement awareness layer
  • Sheriffs/police chiefs no longer routinely informed of NFA acquisitions in their jurisdiction
  • Inconsistent and unauditable behavior (some kept lists, some discarded)   eliminated entirely

Cons
  • NFRTR central registry unaffected   ATF retains every Form 1/4 indefinitely
  • Does not address centralized retention, only local distribution
  • Marginal improvement that doesn't approach the structural concern
Bottom line: Net positive on a narrow axis; doesn't touch the underlying registry problem

The Veteran
Pros
  • Stickier than typical regulatory action because preamble builds explicit "didn't work" record
  • No constituency demanding CLEO notification back   political cost of reversal is real
  • Cekada's first signed rulemaking   clear signaling, institutional weight
  • 4-year horizon: solid
Cons
  • Still regulatory action removable by future regulatory action
  • Lomont authorizes future re-imposition with new factual findings
  • 8-year horizon depends on intervening administrations
  • 12-year horizon genuinely uncertain
Bottom line: More durable than most rules in the package, but not statutory or SCOTUS-grounded; pencil, not ink

The Compliance Cassandra
Pros
  • Unusual rule with minimal risk migration   CLEO notification wasn't load-bearing for any enforcement function
  • CLEOs weren't using info, prosecutors weren't building cases on it, investigators weren't relying on it
  • No new state-level analog likely (no policy hook for states to grab)

Cons
  • Some applicants used CLEO notification informally as a state-law legality check (always flawed but psychologically real)
  • Removes a touchpoint that some treated as backstop verification
  • State-level NFA restrictions unchanged in CA/NY/NJ/IL/etc.

Bottom line: Unusually clean rescission; risk genuinely doesn't migrate anywhere meaningful

Where the panel disagrees:

NFA Guru vs. Privacy Sentinel on whether to call it a "win" without qualification
Litigator vs. Veteran on durability framing (legal vs. political measurement)

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