Comment on FR Doc # 2026-08915

I strongly support the ATF's proposed rule allowing NFA firearm makers to adopt existing manufacturer markings. STATUTORY PLAIN LANGUAGE 26 U.S.C. § 5842(a) requires identification by "the name of the manufacturer, importer, **or maker**"—using the disjunctive "or," not "and." The statute does not require markings from all three parties. When a maker alters an existing firearm, the original manufacturer's markings already satisfy the statutory requirement. The original serial number and manufacturer information enable law enforcement tracing through FFL records. The statute never authorized—and the ATF should never have required—redundant maker engravings. CORRECTING REGULATORY OVERREACH The prior interpretation requiring additional maker markings contradicted the statute's plain language. That the ATF previously issued variances proves it internally acknowledged the requirement was too strict. This rule restores statutory fidelity. There should never have been an engraving mandate in the first place. RETROACTIVE APPLICATION PROTECTS LAW-ABIDING CITIZENS Citizens with pending Form 1 approvals and those unaware of the incorrect requirement should not face enforcement consequences for failing to comply with an unlawful regulation. Retroactive application is legally sound because it removes obligations the statute never imposed. No cure period is necessary—these firearms were always compliant with the statute itself. LAW ENFORCEMENT The original manufacturer's markings provide sufficient traceability. The NFRTR includes maker information regardless of physical engravings. NFA firearms represent a tiny fraction of crime-scene firearms. This rule enhances clarity without compromising enforcement. CLEAR GUIDANCE NEEDED The ATF must explicitly state that: (1) existing markings satisfy § 5842(a); (2) the rule applies retroactively; (3) prior variance applicants are no longer bound by the engraving requirement; and (4) firearms in progress need no additional markings. CONCLUSION This rule is legally sound and overdue. I urge the ATF to finalize it with explicit retroactive application and clear guidance protecting law-abiding citizens from enforcement consequences for the agency's prior misinterpretation of federal law.