News SB Tactical vs the ATF: What Winning Looks Like Forrest Cooper December 23, 2020 Join the Conversation We all have skin in the game with the new letter from the ATF, and perhaps closest to it is SB Tactical. If the Global War on Terror is to teach us anything, it is that we must clearly define what winning looks like, or there will be no end to the conflict. Although it sounds banal, and obvious, one must know what they are aiming at to know if they hit it. Days ago, American gun owners were informed by the ATF that large-frame pistols were facing reclassification as NFA items, and the message did not go unnoticed. There's a touch of irony when the ATF letter proposing clarification needs an interpreter. We spoke with SB Tactical to better understand what winning looks like in this case. What Is At Stake? The letter presented by the ATF has two distinct layers. On the surface, it presents itself as an attempt to clarify what it considers to be a large frame pistol, what counts as a stabilizing brace, and what combination of the two it determines to fall under the National Firearms Act, and the Gun Control Act. Underneath that, it introduces back-door gun registration. For anyone who owns a pistol with a Brace, the proposed clarification could require registration or confiscation, under threat of a felony. For Gun Owners in general, they are facing clear government overreach to impose restrictions outside of legislation. For the economy, 1,000's of Jobs are at stake, and over $1 Billion dollars of civilian sales to be lost across over 100 companies that make and sell large frame pistols. And that revenue isn't just coming out of the pockets of investors as many of those companies use that money to fund their military R&D. And SB Tactical sits directly in the crosshairs, as they produce the most popular Pistol Stabilizing Brace on the market. What Are The Rules Of The Game? SB Tactical has sought clarification and guidance from the ATF and before anyone screams treason, it must be seen as part of a larger strategy. As it stands, the ATF has given their approval on braces as bifurcated flaps and a strap, as well as large-frame pistols, but has remained vague and unclear about the limitations and security of that determination. The request for clarification isn't just to make sure SB Tactical can still sell their product, but to secure an otherwise suspicious relationship between the ATF and American Citizens. The letter from the ATF is framed as a response to that request for clarification, and even if the writing of the letter doesn't reach that end, it has laid the groundwork where U.S. Citizens can challenge and comment on the proposed criteria. If the problem beforehand was that manufacturers of firearms using braces were unsure if or when they would run afoul of the ATF, the new letter is a step in the wrong direction. Until January 4th, Americans can respond to the letter, and their comments will be go to the Department of Justice, who will make a determination. This has happened in the past, and worked in favor of the Public. If we remember the 2015 attempt to ban M855 “green tip” ammunition, it was the voice of the people and their response that made the difference. What Winning Looks Like SB Tactical has laid out what it means for the people to win in this situation. If there is no clarification made regarding the ATF's position on Pistol Stabilizing Braces now, then this will certainly come up again. For years, Braces have thrived under their approval, and considering that millions of Americans own these firearms, the letter is easily interpreted as a registration threat. Reminiscent of the 2015 attempt to ban M855, until the 4th of January when the window for comment closes, it falls on we the people to comment with criticism for the new criteria. Responses that do not use profanity or contain threats will be categorized, sorted and presented to the Department of Justice. The direction of comments should be to pressure the ATF to quantitatively define and classify what constitutes a pistol, and what is considered a brace, challenging the current proposal for including vague or arbitrary criteria such as weight, or optics. For years the standard has held: A screwdriver doesn't become a hammer when used to pound in nails. This current document, as it stands, is untenable as it includes both registration and confiscation. If the ATF is supposed to provide guidance, this isn't it. Guidelines for Submitting Comments to the ATF: Comments including threats and/or profanity will be discarded. Comments that are direct copies of others will also be discarded. They must be original. How To Submit Comment by SB Tactical The full press release from SB Tactical can be found here. DUE DATE: Written comments must be postmarked by, and electronic comments must be submitted on or before January 1, 2021 by midnight Eastern time. INSTRUCTIONS: All submissions received must include the agency name (ATF) and docket number (ATF 2020R-10). All properly completed comments received will be posted without change to the Federal eRulemaking portal, www.regulations.gov, including any personal information provided. Comments must have a full name, mailing address, and signature. Commenters who do not want their name or other personal identifying information posted on the Internet should submit comments by mail or facsimile, along with a separate cover sheet containing their personal identifying information. Both the cover sheet and comment must reference this docket number (ATF 2020R-10). Comments that contain excessive profanity will not be considered or responded to. SUBMISSIONS: Starting December 18, you may submit comments in one of three ways: 1. Online – Federal eRulemaking Portal: ATF recommends that you submit your comments to ATF via the Federal eRulemaking portal at https://www.federalregister.gov/d/2020-27857 and follow the instructions. Please keep the comment tracking number that is provided after you have successfully uploaded your comment. 2. Mail: Written comments must: a. Appear in minimum 12-point font size (.17 inches) b. Include the commenter's first and last name and full mailing address c. Be signed Send written comments to the following address: Office of Regulatory Affairs, Enforcement Programs and Services, Bureau of Alcohol, Tobacco, Firearms, and Explosives ATTN: ATF 2020R-10 Mail Stop 6N- 518 99 New York Ave. NE Washington, DC 20226 3. Facsimile: Faxed comments must: a. Be legible and appear in minimum 12-point font size (.17 inches) b. Be on 8 ½” x 11″ paper c. Include the commenter's first and last name and full mailing address d. Be signed e. Be no more than five pages long More on Pistol Stabilizing Braces and the Actions of the ATF Now is the Time to Act: Decoding the Back-Door Registration Letter. This is what it looks like to be Punished for Good Behavior. Sig Braces, ATF Rulings, and the Inimicable Mr. Kingery. Reason Prevails: The ATF Reverses Its Position on SB Tactical Braces. Q LLC vs the ATF: The Writing on the Wall. Brace Yourself: the creature returns in 2020. Explore RECOILweb:Weekly Deals From Around the Firearms IndustryHonor Defense Rolls Out Ambi SafetiesBlade Show Texas And Texas Gun Experience Team UpSureFire 2012 New Product Video NEXT STEP: Download Your Free Target Pack from RECOILFor years, RECOIL magazine has treated its readers to a full-size (sometimes full color!) shooting target tucked into each big issue. Now we've compiled over 50 of our most popular targets into this one digital PDF download. From handgun drills to AR-15 practice, these 50+ targets have you covered. 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