Comment on FR Doc # 2026-09159

As a FFL, I urge the Bureau to consider these points; First, ATF should make clear that it must establish willfulness before initiating a license revocation proceeding. Revocation itself is extraordinarily costly, even when the dealer ultimately prevails. The process should not become the punishment. Requiring a genuine finding of willfulness before beginning revocation proceedings would help ensure that the abuses associated with the previous “zero tolerance” policy cannot return. Second, ATF should reject any form of strict or vicarious liability that holds a federal firearms licensee responsible for every employee mistake. Congress adopted a willfulness requirement specifically to prevent licenses from being revoked over inadvertent errors. If an employee makes a mistake, the standard should focus on whether the licensee knowingly authorized, directed, or participated in unlawful conduct, not whether ATF later believes the dealer’s corrective actions were “appropriate.” Finally, ATF should reconsider its economic analysis. The proposal significantly understates the financial burden imposed on dealers forced to defend against revocation proceedings. Legal costs can reach tens of thousands of dollars, and some businesses have lost their livelihoods despite acting in good faith. These real-world costs should be accurately reflected in the final rule. I support ATF’s effort to adopt a consistent and meaningful definition of “willfully.” With these additional safeguards, the final rule will better protect law-abiding firearms dealers, respect congressional intent, and help ensure that enforcement is directed at intentional wrongdoing rather than honest mistakes.