Transferring Machine Guns Between Qualified Licensees

The FAIR Trade Group, a trade association of firearms importers and exporters, strongly supports the proposed rule to revise regulations on transferring machine guns between qualified licensees. They argue that the rule correctly aligns with statutory language but request specific refinements regarding inventory maintenance, documentation requirements for government-furnished weapons, and the removal of "sales sample" references.

The Firearms Regulatory Accountability Coalition, Inc. (FRAC) supports the proposed rule as a positive regulatory action but argues it should be amended to align more closely with the statutory language of 18 U.S.C. § 922(o). They contend that the rule should apply the "government authority" exception to all "persons" rather than being arbitrarily restricted to "licensees" (FFLs/SOTs).

The National Shooting Sports Foundation (NSSF), a trade association for the firearms industry, supports the ATF's proposed rule to clarify regulations regarding the manufacture, import, possession, and transfer of machine guns. While they praise the move toward clearer language, they suggest specific revisions to the text to more accurately reflect statutory allowances and avoid potential confusion regarding registration conditions and export activities.

A factory authorized distributor for law enforcement and government entities supports simplifying the transfer of post-1986 dealer sample machine guns to facilitate lawful commerce. The commenter argues that current regulations hinder innovation, subcontracting, and inventory management, and proposes specific changes to improve the supply chain for government and law enforcement agencies.

The commenter supports the proposed action to clarify procedures for transferring machine guns between qualified licensees, though they suggest more radical legislative changes. They express a desire for clearer guidelines for SOT dealers while acknowledging the proposal doesn't go far enough.

The commenter expresses mixed feelings, supporting the ATF's efforts to reduce paperwork and regulatory burdens for manufacturers and dealers while opposing the rule's narrow interpretation of federal and state machine-gun exceptions. They request that the ATF revise the rule to ensure it does not foreclose broader lawful authorization mechanisms permitted by the underlying statute.