Comment on FR Doc # 2026-08912

I write in strong support of the proposed rule to remove the Chief Law Enforcement Officer (CLEO) notification requirement under the National Firearms Act. As both a private citizen and a licensed FFL dealer operating Verso Armament Company in Fairfax County, Virginia, I deal with this requirement on a regular basis, and I can say plainly: it accomplishes nothing, it burdens everyone involved, and it needs to go. The process as it stands requires me to print a copy of the ATF eForm 4 (a form the ATF already receives electronically) and physically mail it to the Virginia State Police Superintendent. For trust-based transfers, I must also mail a separate copy of each responsible person's Form 5320.23. In the age of eForms and digital fingerprints, I am still licking stamps and hoping the postal service gets the job done. There is no logic in requiring physical mail delivery to a state official for a transaction that the federal government has already accepted digitally. The operational friction compounds quickly. The identity of the VSP Superintendent changes with each gubernatorial administration, meaning the name and title in Question 12 of the Form 4 can become stale before the ink dries. There is no centralized, real-time resource that dealers can rely on to confirm the correct current officeholder. Getting this field wrong exposes a dealer to compliance risk for a notification that the receiving agency neither reviews, acts on, nor, in many cases, wants. That last point deserves emphasis. The ATF's own proposed rule acknowledges that CLEOs have raised concerns about inadvertently creating local firearms registries as a result of receiving these forms. I have heard the same sentiment informally from law enforcement contacts. The VSP is not asking for this paperwork. They receive it because a 1934 statute requires it, not because it serves any operational purpose. The CLEO has no authority to approve or deny the transfer, no obligation to act on the notification, and no mechanism to meaningfully use the information in a way that the ATF's own background check process does not already cover. The ATF correctly removed the CLEO notification from Form 1 effective January 1, 2026. Retaining it for Form 4 creates an inconsistency that has no justification. The same applicant, going through the same eForms system, with the same background check, is subject to a paper mailing requirement that depends entirely on which form they happen to be filing. That inconsistency is arbitrary and should be resolved by completing the modernization the ATF has already started. I urge the ATF to finalize this proposed rule without modification and without delay. It removes a procedural burden that imposes real costs on dealers and applicants while producing no public safety benefit. It also eliminates a compliance trap, the stale officeholder problem, that puts well-intentioned dealers at unnecessary risk. This is a straightforward, common-sense change, and it is long overdue.