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Posted: 9/10/2013 10:19:23 AM EDT
When you go to regulations.gov you can view the proposed rule:
ATF 41P

But how do you view the comments that are being submitted over the next 90 days? It shows on the page that 62 comments have been submitted thus far, I would like to read them. Anyone know how?
Link Posted: 9/10/2013 10:33:47 AM EDT
From what I can see the comments have not yet been posted to the page.
Link Posted: 9/10/2013 1:05:40 PM EDT
I posted the comment below:



To whom it may concern,

I am writing you in regards to the public comment period for ATF 41P.  I find that the changes proposed in this rule change adversely impact my family.  I currently have a trust that holds the majority of my NFA collection.  I share the role of co-trustee with my wife.  Two of my soon to be three children have been setup as successor trustees along with my Mother.  The proposed rule change would require that all soon to be six individuals be finger printed, have photos taken, and receive CLEO signoff.  My youngest child is not even born, you would ask me to fingerprint a newborn once she arrives?  You would ask me to finger print my other children who are aged two and five years?  You would have my finger print their elderly grandmother?  I dare say that I feel insulted.  My children are only on the trust as a method of inheritance.  My mother acts a successor trustee to hold the items until my children reach the age of 21 and can act as trustees.  Surely the ridiculousness of the idea of fingerprinting an infant, a two year old, and a five year old for a criminal background cannot be lost upon you.  Surely you see the hardship this would place on my family.  Surely you can understand that such a rule change would be arbitrary and capricious.

My trust explicitly states that any trustee that is or becomes an ineligible person as defined by federal law or state law must be deemed as to have immediately resigned and must immediately surrender all NFA items held on behalf of the trust.  This language in my NFA trust clearly prevents the possibility of a prohibited person from owning or taking possession of NFA items.  This language puts to rest the BAFTE’s fears of prohibited persons using a trust as some kind of legal loop-hole.  I would recommend that instead of requiring finger prints, passport photos, and a CLEO signature for all responsible persons the BATFE require that either:

1)Language similar to that used in my trust is required for NFA trusts.  Prohibiting an ineligible person from being a responsible person.

Or

2)If the trust does not have such language then acting Trustees, not successor trustees or any other member, be required to send in fingerprints, passport photos,  and receive a CLEO signature.  Additionally only acting trustees would be allowed to have access to the NFA items held by the trust.

To conclude, I have outlined the difficulties this trust places upon my family.  The BATFE’s assumption that the new requirements are of limited impact clearly shows that common circumstances for having a trust are being ignored.  The main purpose of a trust is to hold assets for inheritance.  I have also provided a reasonable alternative to the proposed rule change that will allow the BATFE to accomplish its stated goal without placing a burden that ignores the current circumstances of the NFA trust holders.


Link Posted: 9/10/2013 1:30:48 PM EDT
After the 90 comment period ends on Dec. 9, 2013, how quickly can this go into effect?  As much, as we would all like to think there is chance this will not happen, I am pretty sure that it's already a done deal.  Sad times my friends.


Edit - Great Comment above Little Bo Peep!  Nicely done.
Link Posted: 9/12/2013 4:06:42 AM EDT
Quoted:
When you go to regulations.gov you can view the proposed rule:
ATF 41P

But how do you view the comments that are being submitted over the next 90 days? It shows on the page that 62 comments have been submitted thus far, I would like to read them. Anyone know how?
View Quote


On the right side of the page, under "docket information, There is a heading for Related Comments, with a link To See All related comments.
Link Posted: 9/12/2013 5:35:54 AM EDT
Discussion ForumsJump to Quoted PostQuote History
Quoted:


On the right side of the page, under "docket information, There is a heading for Related Comments, with a link To See All related comments.
View Quote View All Quotes
View All Quotes
Discussion ForumsJump to Quoted PostQuote History
Quoted:
Quoted:
When you go to regulations.gov you can view the proposed rule:
ATF 41P

But how do you view the comments that are being submitted over the next 90 days? It shows on the page that 62 comments have been submitted thus far, I would like to read them. Anyone know how?


On the right side of the page, under "docket information, There is a heading for Related Comments, with a link To See All related comments.


And when you go there is still shows zero comments.  Before I send a comment I really want to see what is being posted.
Link Posted: 9/12/2013 6:22:27 AM EDT
As of right now there are 141 comments.
http://www.regulations.gov/#!documentDetail;D=ATF-2013-0001-0001

I tried to post a comment yesterday but kept getting an error
Link Posted: 9/12/2013 4:24:59 PM EDT
Click the open docket folder link
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