Defining `Willfully' for Firearms Violations

The commenter, identifying as a law-abiding gun owner, supports the ATF's proposal to define "willfully" to require actual knowledge of unlawful conduct. They urge the agency to further strengthen the rule by requiring a finding of willfulness before initiating revocation proceedings, rejecting vicarious liability for employee mistakes, and accurately reflecting the high legal costs faced by dealers.

The National Firearms Act Trade and Collectors Association (NFATCA) supports the proposed amendments to clarify the definition of "willfully" in firearms license revocation proceedings. They argue that the proposal provides necessary transparency, consistency, and predictability for Federal Firearms Licensees while improving the organization and readability of the regulation.

The commenter, identifying as a law-abiding gun owner, supports the ATF's proposal to define "willfully" to require actual knowledge of unlawful conduct. They urge the agency to further strengthen the rule by requiring a finding of willfulness before initiating revocation proceedings, rejecting vicarious liability for employee mistakes, and accurately reflecting the high legal costs faced by dealers.

The commenter, identifying as a law-abiding gun owner, supports the ATF's proposal to define "willfully" to require actual knowledge of unlawful conduct. They urge the agency to further strengthen the rule by requiring a finding of willfulness before initiating revocation proceedings, rejecting vicarious liability for employee mistakes, and accurately reflecting the high legal costs faced by dealers.

A Federal Firearms Licensee (FFL) supports the effort to define "willfully" but urges the Bureau to include specific safeguards. The commenter argues that the ATF must establish willfulness before initiating revocation proceedings, reject strict liability for employee mistakes, and more accurately account for the high legal costs of defending against such actions.

The National Rifle Association (NRA) supports the proposed rulemaking to codify a "willful" standard for firearms violations that requires actual knowledge of unlawfulness. They argue this is a necessary corrective to previous "zero-tolerance" policies that led to excessive license revocations for minor, non-material paperwork errors.

The commenter, identifying as a law-abiding gun owner, supports the ATF's proposal to define "willfully" to require actual knowledge of unlawful conduct. They urge the agency to further strengthen the rule by requiring a finding of willfulness before initiating revocation proceedings, rejecting vicarious liability for employee mistakes, and accurately reflecting the high legal costs faced by dealers.

The commenter, identifying as a law-abiding gun owner, supports the ATF's proposal to define "willfully" to require actual knowledge of unlawful conduct. They urge the agency to further strengthen the rule by requiring a finding of willfulness before initiating revocation proceedings, rejecting vicarious liability for employee mistakes, and accurately reflecting the high legal costs faced by dealers.

The commenter supports the ATF's proposal to define "willfully" to distinguish between intentional violations and honest mistakes by firearms dealers. They urge the agency to further strengthen the rule by requiring a finding of willfulness before initiating revocation proceedings, rejecting vicarious liability for employee errors, and accurately reflecting the high legal costs of such proceedings.