The Obama/Holder administration is counting on gun owner apathy to allow proposed changes to Trust/LLC Transfers to go unchallenged. We can’t afford to allow them to divide and conquer gun owners. Gun owners must stand united.

The proposed changes to Trust/LLC transfers will require a law enforcement certification when transferring any title II firearm into a Trust or LLC, this includes suppressors, short-barreled rifles, and machine guns eligible for civilian ownership. This means that if you want to purchase any title II firearm you will need to find a law enforcement official who is willing to provide you with their signature. Most are either too busy, unfamiliar with the law, or believe they will be held politically liable by the anti-gun media and therefore refuse to provide their signature. This is why trust transfers have increased in popularity during the past several years.

Make something hard enough…

You don’t have to outlaw something to force it out of existence. All that is required are standards that are nearly impossible to attain. That is almost certainly the aim of the current administration. Make it so difficult and the liabilities bad enough and no one will want to. While two of the three proposed provisions are acceptable to gun owners and the NFA community, the LE certification represents a serious roadblock. BATFE has proposed changes affecting NFA Trust Transfers that if enacted would require Trust and LLC Transfers to follow guidelines similar to individual transfers in fact:

“The Department of Justice is proposing to amend the regulations of the Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) regarding the making or transferring of a firearm under the National Firearms Act. The proposed regulations would (1) add a definition for the term "responsible person"; (2) require each responsible person of a corporation, trust or legal entity to complete a specified form, and to submit photographs and fingerprints; and (3) modify the requirements regarding the certificate of the chief law enforcement officer (CLEO). [Usually the Sheriff]”

• Go to the ATF comments section of their website, select comments, or paste the following hyperlink into your browser http://www.regulations.gov/#!submitComme...-0001-0001 and use the following comment:

DELIVER THIS MESSAGE

In the matter of 27 CFR Part 479 docket number ATF 41P Part 479, RIN: 1140-AA43, Machine Guns, Destructive Devices and Certain Other Firearms; Background Checks for responsible Persons of a Corporation, Trust or Other Legal Entity With Respect to Making or transferring a Firearm.

I am opposed to any expansion requirement mandating Chief Law Enforcement Officer (CLEO) certification as outlined within the docket. The simple change in verbiage proposed by ATF, would not encourage CLEOs to process applicant paperwork; as there are too many perceived liabilities, political, and professional ramifications associated with NFA firearm acquisition. These unreasonable requirements have created perceptions that have resulted in a measurable decrease of CLEO endorsed transfers. This has contributed to the explosive popularity of Trusts and LLC NFA applications.

The resources available to ATF/NFA including but not limiting to NCIC, TECS, NLETS, III, and NICBCS databases more than adequately ensure that all applicants are fully screened. If any CLEO involvement were required by ATF/NFA the only acceptable process should be CLEO notification post procurement.

This could be accomplished by requiring the successful application to provide the CLEO with a copy of the federal transfer paperwork, or by requiring the name and address of the CLEO being listed on the application form. This name and address would allow ATF/NFA to mail a copy of the applicant’s form to said applicants CLEO upon successful execution of the transfer.