Comment on FR Doc # 2026-08930

I write in support of ATF's proposed rule to remove the factoring criteria framework applied to firearms equipped with stabilizing braces. The 2023 rule was flawed from the outset, both procedurally and substantively. It subjected millions of law-abiding gun owners to retroactive reclassification of legally acquired property. The point-based factoring criteria were arbitrary, internally inconsistent, and offered no reliable guidance to manufacturers, dealers, or consumers trying to comply in good faith. Courts agreed: the Fifth Circuit's decision in Mock v. Garza and subsequent preliminary injunctions in multiple circuits reflected serious constitutional and administrative law concerns the agency never adequately addressed. Stabilizing braces were developed as legitimate accessories for disabled and limited-mobility shooters. The millions of Americans who purchased brace-equipped firearms did so lawfully, often relying on ATF's own prior guidance letters approving their use. Reclassifying those firearms as NFA items and demanding registration, a $200 tax stamp, and potential criminal liability for non-compliance was a disproportionate response to a product the agency had previously approved. The proposed rule correctly identifies that the 2023 framework exceeded ATF's statutory authority. Congress, not the agency, holds the power to expand the NFA's definition of "short-barreled rifle." I strongly support finalizing this rule.