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Remove the CLEO signoff from ATF41P

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The American Silencer Association is asking everyone to do battle with ATF 41P – the executive action issued by the Obama Administration last August 29th seeking to amend the transfer of NFA firearms. It was published in the Federal Register on September 9th and the public comment period, which lasts 90 days, comes to a conclusion this Monday (December 9th).

Included in ATF 41P is an amendment to require a Chief Law Enforcement Officer (CLEO) signoff for all NFA transfers, including those conducted by a trust or legal entity…ATF 41P…the definition of a responsible person (RP), and requires that all RP’s submit fingerprints, passport photos, and to a background check for all transfers. While the ASA does support background checks, it unequivocally opposes CLEO signoff requirements for any NFA transfer. Additionally, without offering any monetary compensation to local Law Enforcement Agencies for their time, this onerous proposal will unnecessarily burden these agencies with yet another layer of bureaucratic paperwork.

If you are unfamiliar with this proposed NFA rule change,  you can read the entirety of the ASA's statement discussing ATF 41P here.

Please take a few minutes to read the following message from the ASA and help remove the CLEO signoff requirement from the proposal by submitting comments to the Federal Register.

Since ATF 41P was published in the Federal Register, the ASA has been working with industry to coordinate support against sections of the proposed rule change. Part of our coordination included drafting two user adjustable comment templates for individuals. Click the links to download:

41P Comment Template – Individual with Legal Entity

41P Comment Template – Individual without Legal Entity

Because form letters do not carry as much weight in the commenting process as customized letters, the ASA created hybrids, which give individuals a template, but still allow them to tailor their comments. If parts of the template do not apply to you, simply change or delete them before submitting.

Here is an example of a completed comment template. Note that non-applicable information has been removed by the individual.

The ASA encourages all individuals to submit comments to BATFE on the proposed rule change. If you would prefer to submit your own comment, please be respectful in your submission.

To submit, there are several available methods. You may submit comments, identified by docket number (ATF 41P), by any of the following methods:

  1. Federal eRulemaking Portal 
  2. Fax: (202) 648-9741
  3. Mail: Brenda Raffath Friend, Mailstop 6N-602, Office of Regulatory Affairs, Enforcement Programs and Services, Bureau of Alcohol, Tobacco, Firearms, and Explosives, U.S. Department of Justice, 99 New York Avenue NE., Washington, DC 20226; ATTN: ATF 41P.
All submissions must include the agency name, Bureau of Alcohol, Tobacco, Firearms and Explosives, and the docket number for this rulemaking, ATF 41P. All comments received will be posted without change to the Federal eRulemaking portal, including any personal information provided. For additional information about the comment and rulemaking process, click here.
The comment period ends at 11:59 p.m. Eastern Time on Monday, December 9. Be sure to make your voice heard before then.
See also this article on the topic by the NRA-ILA.
American Sniper Association

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