Regulations Defining Engaged in the Business as a Dealer in Firearms

The National Firearms Act Trade and Collectors Association (NFATCA) supports the proposed rule to clarify the definition of "engaged in the business" as a dealer in firearms. They argue that the rule aligns with existing statutes and protects individuals from being criminalized for enhancing personal collections.

Gun Owners of America and Gun Owners Foundation oppose the proposed rule, arguing that it fails to sufficiently walk back the unlawful legal theories of the previous "Biden rule." They contend that the NPRM still allows for the criminalization of private gun owners by maintaining atextual interpretations regarding "engaged in the business" and "former licensee inventory."

The commenter, a private firearm collector, opposes the proposed rule because it preserves legal theories they believe were already rejected by the courts. They argue that the rule still unfairly targets law-abiding individuals by allowing personal collection activities to be used as evidence of unlicensed dealing.

The commenter opposes the proposed rule, arguing that it deregulates firearm sales and removes enforcement tools used to identify unlicensed dealers. They express concern that this will make it easier for prohibited individuals to obtain weapons and facilitate firearms trafficking.

The commenter, an individual who recently administered a firearm estate, opposes the proposed rule because it preserves legal theories they believe were already rejected by the courts. They argue the rule could unfairly expose innocent individuals to prosecution and urge the ATF to rescind the previous framework entirely in favor of a rule that follows plain statutory language.