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Posted: 9/6/2013 9:22:05 AM EDT
https://www.federalregister.gov/articles/2013/09/09/2013-21661/background-checks-for-responsible-persons-of-a-corporation-trust-or-other-legal-entity-with-respect

More information incoming. I will be giving away a couple of gift cards to a random member who contacts the ATF/reps/CLEO during the 90 day period.

Here is the deal:
Starting Monday, September 9, we need to hit the comment period hard for ATF 41P! Instructions for submitting comments are at the bottom of this post. I will be giving out two gift cards to randomly selected members who submit comments. Please see the next section for how this will work.

Rules for giveaway:
Winners will be selected at random.
Members who contact ATF/Representatives/Senators/Governors/CLEOs/etc. will receive tickets for each letter. Tickets are essentially entries into the drawing. To get tickets, simply post in this thread with a SENT - (name and office of person contacted). Tickets will be awarded as follows:
Contact ATF - 3 Tickets
Any other contact - 1 Ticket

At the end, I will randomly select winners using Excel/VBA-fu. In effort to stay more transparent than the current administration, I will post my code before the selection.

What is to be had:
$35 Gift Certificate to site sponsor Bravo Company USA
$25 NRA Bass Pro Gift Card

Suggested talking points incoming

1. Proposal modifies intent of law without Congress (See Here)
2. Number of people on your trust (if you have one)(ATF estimates 2 per)
3. CLEOs refuse to sign due to politics, not for fear of liability. Remind them CLEOs are political figures.
4. Proposal necessitates legal action against CLEOs or ATF by some.
5. Possible violations of trust law
6. Puts CLEOs in charge of who may be added to a trust/corp/LLC. CLEOs and ATF will be meddling with people's estate planning.
7. ATF admits it already has tools to do BG checks.
8. Will place much greater burden on CLEOs
9. Loss of tax revenue

Instructions for letter submission (thanks tReznr):

ADDRESSES: You may submit comments, identified by docket number (ATF41P), by any of the following methods-

•Federal eRulemaking Portal: http://www.regulations.gov. Follow the instructions for submitting comments.

•Fax: (202) 648-9741

•Mail: Brenda Raffath Friend, Mailstop 6N-602, Office of Regulatory Affairs, Enforcement Programs and Services, Bureau of Alcohol, Tobacco, Firearms, and Explosives, U.S. Department of Justice, 99 New York Avenue, NE, Washington, DC, 20226;
ATTN: ATF 41P
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Instructions: All submissions received must include the agency name and docket number for this rulemaking. (ATF 41P)
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Mail: Send written comments to the address listed in the ADDRESSES section of this document. Written comments must appear in minimum of 12 point font size/ (.17 inches), include your mailing address, be signed, and may be of any length.
Facsimile: You may submit comments by facsimile transmission to (202) 648-9741
Federal eRulemaking Portal: To submit to comments to the ATF via the Federal eRulemaking portal visit http://www.regulations.gov and follow the instructions for submitting comments.
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Get at it ARFCOM!
Link Posted: 9/6/2013 9:32:42 AM EDT
[#1]
I will be sending letters/emails ASAP. Of course this BS has to happen right just as I'm finally preparing to move to a state that allows NFA
Link Posted: 9/6/2013 9:34:21 AM EDT
[#2]
Thanks for the info. Looks like it's time to fire up the letter writing machine.
Link Posted: 9/6/2013 9:46:08 AM EDT
[#3]
Quoted:
https://www.federalregister.gov/articles/2013/09/09/2013-21661/background-checks-for-responsible-persons-of-a-corporation-trust-or-other-legal-entity-with-respect

More information incoming. I will be giving away a couple of gift cards to a random member who contacts the ATF/reps/CLEO during the 90 day period.
View Quote


WE NEED TO GET TACKY, SO WE CAN KEEP THE FIGHT UP FRONT


Link Posted: 9/6/2013 9:52:25 AM EDT
[#4]
Discussion ForumsJump to Quoted PostQuote History
Quoted:


WE NEED TO GET TACKY, SO WE CAN KEEP THE FIGHT UP FRONT


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Discussion ForumsJump to Quoted PostQuote History
Quoted:
Quoted:
https://www.federalregister.gov/articles/2013/09/09/2013-21661/background-checks-for-responsible-persons-of-a-corporation-trust-or-other-legal-entity-with-respect

More information incoming. I will be giving away a couple of gift cards to a random member who contacts the ATF/reps/CLEO during the 90 day period.


WE NEED TO GET TACKY, SO WE CAN KEEP THE FIGHT UP FRONT



Link Posted: 9/6/2013 9:53:51 AM EDT
[#5]

Quoted:


https://www.federalregister.gov/articles/2013/09/09/2013-21661/background-checks-for-responsible-persons-of-a-corporation-trust-or-other-legal-entity-with-respect



More information incoming. I will be giving away a couple of gift cards to a random member who contacts the ATF/reps/CLEO during the 90 day period.
View Quote


I'd be ok with it honestly (including the doing away with CLEO sign off) if they issued stamps at the POS after a phone in background check.



 
Link Posted: 9/6/2013 9:54:45 AM EDT
[#6]
Link Posted: 9/6/2013 9:55:06 AM EDT
[#7]
I'll be more than happy to comment on this!
Link Posted: 9/6/2013 9:55:47 AM EDT
[#8]
Discussion ForumsJump to Quoted PostQuote History
Quoted:

I'd be ok with it honestly (including the doing away with CLEO sign off) if they issued stamps at the POS after a phone in background check.
 
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Discussion ForumsJump to Quoted PostQuote History
Quoted:
Quoted:
https://www.federalregister.gov/articles/2013/09/09/2013-21661/background-checks-for-responsible-persons-of-a-corporation-trust-or-other-legal-entity-with-respect

More information incoming. I will be giving away a couple of gift cards to a random member who contacts the ATF/reps/CLEO during the 90 day period.

I'd be ok with it honestly (including the doing away with CLEO sign off) if they issued stamps at the POS after a phone in background check.
 

Yup
Link Posted: 9/6/2013 9:56:25 AM EDT
[#9]
Tag
Link Posted: 9/6/2013 10:22:23 AM EDT
[#10]

Discussion ForumsJump to Quoted PostQuote History
Quoted:





I'd be ok with it honestly (including the doing away with CLEO sign off) if they issued stamps at the POS after a phone in background check.

 
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Discussion ForumsJump to Quoted PostQuote History
Quoted:



Quoted:

https://www.federalregister.gov/articles/2013/09/09/2013-21661/background-checks-for-responsible-persons-of-a-corporation-trust-or-other-legal-entity-with-respect



More information incoming. I will be giving away a couple of gift cards to a random member who contacts the ATF/reps/CLEO during the 90 day period.


I'd be ok with it honestly (including the doing away with CLEO sign off) if they issued stamps at the POS after a phone in background check.

 




 
On the face of it, I would sort of agree, but my paranoia leads me to believe this is just the first step in something bigger.




If they can get approval to require background checks on responsible parties for trusts, what's to prevent them from making it retroactive?  Why not a new requirement that any existing trusts owning NFA items now need to "certify"?




And how do they intend to handle changes in trustees, etc., for trusts that have already been approved?




This opens too many new doors, and just needs to be shot down entirely.












Link Posted: 9/6/2013 10:37:44 AM EDT
[#11]
Ideally there would be a way to show the danger the proposed changes would cause to existing and traditional corporate law outside the NFA situation.  Perhaps something like owning a corporation or trust and only being permitted to transfer the corporation or elect officers who meet the government's approval.  In the same way with the trust situation, If this would pass, A trustee would need to be approved by the government before they could serve in that position.  It is important for us to remember that the standards used today to pass the law can easily be changed in the future.

The US government has a no fly list.  Who determines who is permitted to fly on a plane?  How can one be removed from the list?  What is the criteria for being placed on the list?  Does anyone actually know?  -  Coming soon to an NFA (or any other) trust / Corp near you.
Link Posted: 9/6/2013 10:42:37 AM EDT
[#12]
Discussion ForumsJump to Quoted PostQuote History
Quoted:
Ideally there would be a way to show the danger the proposed changes would cause to existing and traditional corporate law outside the NFA situation.  Perhaps something like owning a corporation or trust and only being permitted to transfer the corporation or elect officers who meet the government's approval.  In the same way with the trust situation, If this would pass, A trustee would need to be approved by the government before they could serve in that position.  It is important for us to remember that the standards used today to pass the law can easily be changed in the future.

The US government has a no fly list.  Who determines who is permitted to fly on a plane?  How can one be removed from the list?  What is the criteria for being placed on the list?  Does anyone actually know?  -  Coming soon to an NFA (or any other) trust / Corp near you.
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Exactly this. Since additions to the trust are required to submit CLEO approval, what happens if they cannot get it. At that point, the government is dictating who can/cannot be part of a legal entity and is also imposing on who may be part of an inheritance. This is worrisome beyond an NFA standpoint.
Link Posted: 9/6/2013 1:51:19 PM EDT
[#13]
Updated with more information. Please note my instructions for receiving tickets. I would like to make sure everyone formats their posts properly so I do not miss anyone.

I will be pulling in some talking points tonight and tomorrow.
Link Posted: 9/6/2013 4:18:35 PM EDT
[#14]
Discussion ForumsJump to Quoted PostQuote History
Quoted:


I'd be ok with it honestly (including the doing away with CLEO sign off) if they issued stamps at the POS after a phone in background check.  
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Discussion ForumsJump to Quoted PostQuote History
Quoted:
Quoted:
https://www.federalregister.gov/articles/2013/09/09/2013-21661/background-checks-for-responsible-persons-of-a-corporation-trust-or-other-legal-entity-with-respect
More information incoming. I will be giving away a couple of gift cards to a random member who contacts the ATF/reps/CLEO during the 90 day period.  


I'd be ok with it honestly (including the doing away with CLEO sign off) if they issued stamps at the POS after a phone in background check.  


I can see a realistic argument to make stamps for silencers, SBRs and SBSs a point of sale issue-on-approval transaction.  Class III weapons could never be considered for such treatment without a monstrous political fight that would probably kill the entire issue of easing any NFA requirements.
Link Posted: 9/7/2013 8:38:32 PM EDT
[#15]
Less than 24 hours gentlemen. Be sure to read the proposal and that you have a good understanding of it before commenting. Remember, we have 90 days so it is not a rush. Just make sure you do send something.
Link Posted: 9/7/2013 8:39:56 PM EDT
[#16]
Does telling them to get fucked count. They might have unblocked me by now
Link Posted: 9/7/2013 8:44:55 PM EDT
[#17]
Discussion ForumsJump to Quoted PostQuote History
Quoted:
Does telling them to get fucked count. They might have unblocked me by now
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Haha I wish I could say it did. Since they must respond to these, we really need to be sure we are giving them tough comments.
Link Posted: 9/9/2013 5:25:57 AM EDT
[#18]
Comments open today. Going to give this a bump to the top.
Link Posted: 9/9/2013 5:27:15 AM EDT
[#19]
Link Posted: 9/9/2013 5:31:03 AM EDT
[#20]
Someone write me up something worthwhile and I'll send it.
Link Posted: 9/9/2013 5:31:17 AM EDT
[#21]
Tagged to post link to sample comments.
Link Posted: 9/9/2013 5:35:35 AM EDT
[#22]
I'm. Not exactly creative or thought provoking when it comes to these things. Are there any good copy/paste or examples floating around?
Link Posted: 9/9/2013 7:26:11 AM EDT
[#23]
Discussion ForumsJump to Quoted PostQuote History
[b]WE NEED TO GET TACKY, SO WE CAN KEEP THE FIGHT UP FRONT


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Yes, can we get this tacked please!

TriumphRider
Link Posted: 9/9/2013 7:26:35 AM EDT
[#24]
Double tap...
Link Posted: 9/9/2013 7:27:36 AM EDT
[#25]
Don't stop at comments. Call and write your representatives, make as much noise about this as possible.
Link Posted: 9/9/2013 7:30:22 AM EDT
[#26]
Taggage.


Link Posted: 9/9/2013 7:54:33 AM EDT
[#27]
Hit
Link Posted: 9/9/2013 10:08:56 AM EDT
[#28]
Letter going out tomorrow morning
Link Posted: 9/9/2013 10:43:30 AM EDT
[#29]
I'm in.
Link Posted: 9/9/2013 12:10:46 PM EDT
[#30]
Tag for letter writing
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