End of comment period coming monday

Laxguy59

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Text taken from Kort at Silencerco.

On August 29, 2013, the Obama Administration issued an executive action that seeks to amend the transfer of NFA firearms. Known as ATF 41P, it was published in the Federal Register on September 9. The public comment period, which lasts 90 days, will come to a conclusion on Monday, December 9.

To help, please voice your opinion by submitting a comment to the Federal Register. Directions, and two draft comments for individuals, can be viewed here: http://americansilencerassociation.com/how-to-comment-against-atf-41p/
 
Pulled this off of AR15.com

1. Go to regulations.gov
2. Search "ATF 41P”
3. Click on the comment box and leave your opinion

I submitted mine and will be mailing it in tomorrow. Total comments at 5124.

Here is a copy of the comment I left, feel free to copy/add to it:

I am opposed to the Bureau of Alcohol, Tobacco, Firearms and Explosives proposed rule, docket number ATF 41P, on transfers of NFA firearms to “legal entities” such as trusts and corporations. I have considered creating a “legal entity” to possess NFA firearms and my experience tells me ATF is wrong on several key issues.
First, I believe ATF is incorrect in saying that law enforcement officials only refuse to sign off due to liability fears. That was not my experience. In Cherokee County, Georgia, the Cherokee County Sheriff refuses to sign off on these transfers because of the liability that he takes on by doing so.
ATF also estimates an unrealistically low cost for photographs and fingerprints. ATF estimates that photographs would cost $8.00 and take an average of 50 minutes to obtain, and that fingerprints would cost $24.00 and take 60 minutes to obtain. In my experience, the costs and times are higher. I learned that it would cost me $15.00 to get photographs, which took 60 minutes to obtain. It also would have cost me $50 to get fingerprints, which took me 120 minutes.
All of those costs have to be multiplied by the number of “responsible persons” on the application. ATF estimates only two responsible persons per legal entity. I believe that is a very low estimate. Had I chosen to create a Trust, it would have included three (3) people who would qualify as “responsible persons” under ATF’s definition.
Another major problem in the proposed rule is the definition of “responsible person.” Although the wording is different for different types of entities, generally ATF’s definition would include anyone who “possesses, directly or indirectly, the power or authority … to receive, possess, ship, transport, deliver, transfer, or otherwise dispose of a firearm for, or on behalf of” the entity. The laws on trusts and corporations are very complex. In my case, it would be very difficult for me to say accurately which of the parties in my Trust would have fallen under this definition. What happens if I pass away and my wife and child are not listed as beneficiaries, yet the firearms and/or suppressors which I have are located in the house, which they live in? NFA trusts are often used to ensure that a child may inherit the assets of the trust from a deceased parent. They are valuable tools for estate planning, and beneficiaries should not have to submit to these violations of their civil liberties simply because they have inherited private property. To get a clear answer on that, I would probably have need to speak with a lawyer-another cost that ATF fails to consider.
I appreciate your attention to my comments and I hope ATF will reconsider this process. I unequivocally oppose CLEO signoff requirements for any NFA transfer, and suggest the elimination of the CLEO signoff requirement in its entirety. Allowing government officials to unilaterally deny otherwise lawful firearms transfers to citizens flies in the face of the core American principle that we are a nation of laws, not men. This should not be allowed to stand.
 
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