Comment on FR Doc # 2026-09158
Matt MosakowskiOpposeIndividual
Summary: An individual commenter opposes the proposed electronic recordkeeping rule, arguing that digitizing firearm transaction records could facilitate the creation of a de facto national firearms registry and increase privacy risks. They suggest that if record-keeping is burdensome for FFLs, the agency should instead consider changing the required retention period.
I oppose ATF's proposed electronic recordkeeping rule (RIN 1140-AA94).
While electronic records may improve convenience for licensees, they also significantly increase the potential for aggregation, searching, and centralization of firearm transaction records in ways that were not possible with decentralized paper records.
Congress prohibited the creation of a national firearms registry through federal law. The practical effect of widespread digitization of firearm records could undermine the spirit of those protections by making future centralized ownership databases technically simple to create.
I am concerned that electronic and cloud-based storage of firearm transaction records increases privacy risks for lawful firearm owners and creates opportunities for future misuse by government agencies or unauthorized third parties through data breaches or policy changes.
The burden of preserving constitutional protections should not depend solely on the current intentions of regulators or future administrations.
For these reasons, I urge ATF to withdraw this proposed rule and maintain existing restrictions on electronic recordkeeping practices that reduce the risk of creating a de facto federal firearms registry.
If storing records is becoming too burdensome for FFLs then we need to change the record keeping time period requirement.