Can someone sum it up in simple terms for this tired old dumb electrician?
Like...and they trying to say uppers now have to have SN#...and what not?
There are several issues in the rule change.
First, they are beginning from an assertion that PMF (Personally Made Firearms) are being discovered at an increasing number of crime scenes. They do not clarify how adding serialization will change that condition
One is that they want to add the word "readily" to the definition of what is a "recognizable" gun part. And that they don't want to actually define how they mean "readily." So, is that a bored dude with a file, or a Master Machinist with a full machine shop. Is it 15 minutes or 15 days. They want to eat the cake and have it , too.
Another is that they want all "recognizable" gun parts that can be "readily" assembled into a firearm serialized. That means people who run a machine shop selling as subcontractors as well hobbyists. Just which parts are not defined at all. Conversion cylinders, Magazine conversions, stock conversions, etc.
A fillip to the above is that the number and agreement of serialization is not defined. Let's say you have an XXX brand buffer tube, under the proposed new rule, it needs an s/n. Let's suppose you also buy a "conversion" carbine-length gas tube, which might need a serial. Which serial applies? If you pull an upper off a serialized lower, doe the new upper need to be serialized to the lower? None of that is defined.
Also, they want FFL to retain records forever, and not just 20 years. They also want to create a new Federal category of Serial Number makers, who will be guaranteed work in serializing anything requiring temporary or permanent Transfer.
Now, they tossed a carrot in with the sticks. The only good portion of this Rule Change would be that suppressors would only be identified by their tube or outer assembly., the internal bits would not each be considered suppressors
per se, as they are now. Under the new rule, you could have spare baffles, or more than one muzzle adapter (maybe).
I have summarized this in this way, as these are the sorts of thing that ought to be addressed, point by point, in the Public Comments area, which is meant to be accessible to all of the general public (I need to find the link). Procedural rules require ATFE to answer every Comment made on this rule change.
Note, too, I include the carrot. ATFE ought be praised for a sensible change to how suppressors are regulated. Then, castigated for the less-good items noted above.