Comment on FR Doc # 2026-09158

To the Office of Regulatory Affairs: I am writing as a member of the public to express support for the proposed rule revising the non-over-the-counter (NOTC) transaction requirements under 27 CFR 478.96. I urge the Bureau to finalize this rule substantially as proposed. As the notice correctly observes, 18 U.S.C. 922(c) contains no textual limitation restricting NOTC transfers to NICS exempt transactions. The statute requires only that a transfer not be otherwise prohibited, that the transferee submit the required sworn statement, and that the licensee notify the transferee's chief law enforcement officer. Nothing in the statutory language ties NOTC eligibility to the NICS exemption categories found in section 922(t)(3). The current regulation's narrower reading was a policy choice layered onto the statute, not a requirement compelled by it. Aligning the regulation with the statute as written is the correct outcome as a matter of sound administrative practice, independent of any policy preference. The rule ties eligibility to identity verification meeting NIST Special Publication 800-63-4 at Identity Assurance Level 2, with Authentication Assurance Level 2 for returning customers. These are the same standards already relied upon by the IRS, the Small Business Administration, and other federal agencies for verifying identity in connection with legally and financially consequential transactions. Requiring a live videoconference in which the licensee personally examines the photo identification document, combined with third party verified biometric binding, is if anything a more rigorous identification step than the current in person practice, which relies solely on a visual comparison by store staff with no external verification layer at all. The rule does not weaken the identification requirement; it modernizes and in some respects strengthens it. It is worth emphasizing for the record that this proposal does not remove any safeguard required by the Gun Control Act or the Brady Act. Every NICS background check obligation remains fully in place. Every CLEO notification obligation under section 922(c)(2) remains fully in place. Form 4473 remains required. The rule changes how a transferee's presence and identity are established prior to those checks; it does not narrow who is eligible to receive a firearm or reduce any check that a prohibited person would otherwise have to pass. The Bureau's Regulatory Impact Analysis estimates approximately 3.99 million hours in annual time savings for buyers, translating to roughly 103.7 million dollars annually and just over 1 billion dollars over ten years. These are real costs currently borne by lawful purchasers, particularly those in rural areas, those with mobility limitations, and those simply seeking a firearm not available at a nearby dealer. Because adoption by both dealers and buyers remains entirely voluntary, this benefit is realized without imposing any new obligation on licensees who prefer to continue operating as they do today. For the reasons above, I support finalizing RIN 1140-AB05 as proposed. The rule corrects an unnecessarily narrow regulatory restriction not required by the statute, applies a modern and well tested identity verification standard, preserves every existing background check and notification safeguard, and delivers substantial, quantifiable savings to lawful purchasers on a purely voluntary basis. I appreciate the opportunity to comment and thank the Bureau for its consideration. Respectfully submitted,