Comment on FR Doc # 2026-09157

I strongly oppose the ATF's proposed rule regarding Non-Over-the-Counter Firearms Transaction Requirements. As a Federal Firearms Licensee (FFL) with more than 20 years of experience, I believe this proposal would weaken—not strengthen—the safeguards that currently exist to prevent firearms from falling into the wrong hands. Licensed firearms dealers are the first line of defense against illegal firearm purchases. Every day, we interact face-to-face with customers, verify identification, compare photographs, assess behavior, ask questions when necessary, and identify potential straw purchasers or other suspicious transactions. These personal interactions are often what prevent prohibited individuals, traffickers, and cartel associates from obtaining firearms through legitimate channels. Removing or reducing those in-person safeguards shifts responsibility to third-party carriers and contract delivery personnel who are neither trained nor licensed to recognize indicators of straw purchases or fraudulent transactions. Mail carriers and contract delivery drivers are not firearms compliance professionals, nor should they be expected to make the judgments that experienced FFLs make every day. This proposal also creates significant security concerns. Thousands of firearms are already reported lost or stolen each year while in transit to licensed dealers. Expanding direct delivery to residences would create an attractive target for organized theft and so-called "porch pirates." Criminals monitor package deliveries today, and firearms shipments would become among the most valuable items they could steal. Rather than reducing illegal firearms trafficking, this proposal could unintentionally increase the number of stolen firearms entering the criminal market. In addition, verifying the identity of the intended recipient at a residence presents practical challenges. Delivery personnel are often under significant time pressure, and the consistency of identity verification varies widely depending on the carrier, the individual employee, and whether the delivery is handled by a contractor. A signature alone does not provide the same level of scrutiny and accountability as an in-person transfer conducted by a licensed firearms dealer. The current FFL transfer process has proven effective because it combines a NICS background check with an in-person verification by a trained, federally licensed dealer who is legally responsible for ensuring the transfer complies with federal law. Weakening that process removes an important layer of protection that has helped prevent countless illegal firearm transfers. If the ATF's objective is to reduce firearms entering the hands of prohibited persons, the agency should focus on strengthening enforcement against straw purchasers, firearms traffickers, and violent criminals rather than eliminating the face-to-face safeguards provided by licensed dealers. For these reasons, I respectfully urge the ATF to withdraw this proposed rule and preserve the existing in-person transfer requirements that have long served as one of the most effective protections in the federal firearms regulatory system.