Comment on FR Doc # 2026-09159

The National Firearms Act Trade and Collectors Association (NFATCA) supports the proposed amendments clarifying the meaning of the term "willfully" as used in 27 C.F.R. § 478.73. Greater regulatory clarity regarding the standard governing license revocation proceedings is an important objective that benefits both the regulated community and the Bureau. The concept of willfulness has long been a source of uncertainty for Federal Firearms Licensees (FFLs). Although the term has been interpreted in judicial decisions addressing both civil and criminal matters, those interpretations have arisen in different statutory and procedural contexts and have not always provided a clear framework for licensees seeking to understand the conduct that may subject them to administrative enforcement. In addition, changes in enforcement priorities over time have contributed to differing perceptions regarding how the willfulness standard is applied in practice. Providing a clear regulatory definition promotes transparency, consistency, and predictability in the administration of the Gun Control Act. NFATCA supports ATF's proposal to define the term within § 478.73, where it is specifically applied, rather than in the general definitions section of Part 478. Locating the definition in the regulatory provision governing license denial and revocation proceedings makes the standard more accessible and easier for licensees to understand in its proper context. Likewise, the proposed explanatory provisions addressing repeated violations, willful blindness, and conduct attributable to individuals with supervisory authority provide useful guidance regarding the circumstances under which conduct may rise to the level of willfulness. These clarifications should assist licensees in developing effective compliance programs while promoting more consistent application of the regulation by both the regulated community and the agency. NFATCA also supports ATF's proposed restructuring of § 478.73 to improve its organization and readability. Separating the existing text into discrete subparagraphs and incorporating plain-language revisions enhances the regulation's usability without altering its substantive requirements. Improvements to the organization and presentation of regulatory text reduce ambiguity and facilitate compliance. More broadly, NFATCA believes that clearly articulating the standard governing administrative enforcement advances fundamental principles of due process and sound administrative practice. Regulated parties should be able to understand the legal standards by which their conduct will be evaluated and the circumstances under which enforcement action may be taken. By providing a more precise and transparent explanation of the willfulness standard, the proposed rule advances that objective. Accordingly, NFATCA supports adoption of the proposed amendments.