Comment on FR Doc # 2026-08925

Kel-Tec CNC Industries, Inc.SupportBusiness
Summary: A firearms manufacturer with multiple buildings on a single campus argues that the current requirements for separate FFLs based on street addresses create unnecessary and redundant recordkeeping. They support the proposed changes to allow a single FFL to cover a single manufacturing operation across adjacent buildings on a unified campus.
We are currently a firearms manufacturer of over 35 years. Over the course of time, we have grown from a single building to five. Four of the buildings are contiguous to each other, but technically have separate street addresses. The entire campus is within a single fence. Our 5th building has an unaffiliated business separating it from our main campus. Currently we have 3 separate FFLs, and an offsite storage variance in order to conduct our single firearm manufacturing operation. One FFL is to operate our warranty department in one building. Another is for the final assembly and shipping of new production, currently in its own building. And the 3rd is so that our CNC facility can manufacture suppressor baffles, which subsequently required a separate SOT, even though right next door we have an active FFL and SOT. In the event a warranty firearm needs a replacement frame, we have log it out and then back in between FFLs. We often times get firearms sent to the wrong FFL, where we have to log it into one A&D record, log it back out, then log it into another A&D record. This is one single firearm manufacturing operation, but we have triple the recordkeeping because the buildings happen to have separate street addresses. I'm certain that the intent of the current rule was never to have an FFL have to maintain transfer records between it's adjacent buildings. It most certainly is operation based and to keep track of the various business entities a firearm travels through. If it is a single operation on an obvious campus, then it makes logical sense for a single FFL to cover the one operation. I strongly support the proposed changes for obvious reasons. Applying for an FFL already requires a site visit and therefore would be incredibly easy for an inspector to verify whether a single FFL would be appropriate.

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