CapnMac
Member
The comments ought address specific issues within the rule change. Unenforcibility is an excellent one to object to. The unclear nature of what markings need to be made, and where, and by whom is worth commenting upon.Remember in a proposed rule making that ATF must respond to all comments.
The additional burden on FFL to keep Records forever, and how that affects the FFL who are currently compliant to 20 years as a separate class, is worth pointing out.
The better written the comment is, the less likely it is to be dismissed with a Form Letter (all Federal Rule-Making Agencies are required to Answer questions raised in the public comment period). The need to answer all of the Comments raised in response to the M885 Rule is why that Rule Change was withdrawn. The volume of Comments was higher than they could answer in the allotted time period.
I'm sure Matt at Fuddbusters will have a cogent video out on this soon.
Except that this rule change was ginned up last year, the leaked Draft of this was dated in December.It's exactly what I expect out of this administration.
Admittedly, the current Administration is unlikely to ask ATFE to slow down, but this was in motion before November/