Comment on FR Doc # 2026-08918

I support this proposed rule so long as long-duration state permits, including the Illinois FOID card, are recognized when the state conducts the required recurring eligibility verification. The purpose of the NICS alternate permit exception is to avoid duplicative background checks when a state-issued permit already confirms that the holder may lawfully possess or acquire firearms. ATF’s proposed rule appropriately recognizes that permits issued for more than five years may still qualify if state law requires verification or reverification within the previous five years and the permit holder can document that reverification. This clarification is important for states like Illinois. The Illinois FOID card is generally a 10-year card, and Illinois State Police states that a FOID can remain active for 10 years from the date of a firearm transfer inquiry approval when the cardholder has fingerprints on file and is not subject to suspension or revocation. Illinois rules also provide that when a FOID holder is approved for a new or renewed concealed carry license, the FOID is automatically renewed for 10 years from that approval. Because of that structure, ATF should make clear that a state permit should not be disqualified merely because the card itself is nominally valid for more than five years. If the state performs a new background check, reverification, automatic renewal, or other official eligibility confirmation within the prior five years, that should satisfy the federal requirement for a permit issued within the previous five years. The important question should be whether the issuing authority has recently confirmed eligibility, not whether the physical card uses a shorter expiration period. I also support ATF’s clarification that permits must be valid and unexpired, and that ATF should look to the actual law of the state when determining whether a permit qualifies. A state should not lose recognition as a NICS alternate permit system merely because a permit was erroneously issued in an isolated case. The proper inquiry is whether state law requires an authorized official to verify that the permit holder is not prohibited. For these reasons, I support finalizing the proposed rule, with clarification that permits like the Illinois FOID may qualify when state law provides recurring eligibility checks, automatic renewal after a qualifying firearm purchase background check, or extension upon concealed carry license approval or renewal. The rule should preserve the NICS alternate permit option for states that perform meaningful and recurring eligibility verification, even when the state card itself is valid for more than five years.