I’ve done a bit of research into this topic, to see exactly how we could be affected by any change in ATF’s stance toward type 03 Federal Firearms Licensees.
Stepped up inspections of C&R FFL holders would be the most obvious way to make licensing uncomfortable enough that a lot fewer people would want to do it.
They could also change the C&R terms. Title 18, Chapter 44 pretty much leaves this up to the Attorney General, but the standards for a firearm to qualify as a Curio and Relic are part of the Code of Federal Regulations, and to change it would require going through the rulemaking process.  This can be done without an Act of Congress, however, but ATF can’t (at least not without getting into areas of questionable legality, so that’s not to say it couldn’t happen) unilaterally alter the requirements for being on the list.
Eliminating the Curio and Relic license, changing the fee, or adding requirements to own a safe or other such things, would require an Act of Congress.
So my guess is, if ATF is going to start publicaly going after C&R licensees, it’ll likely involve the rubber glove treatment using the inspection powers they already have. Â Make you all your C&R holders out there are keeping your paperwork in good order, which you should really be doing anyway.
Maybe you are right, but it seems to me that the BATFE would be more interested in collecting the fees from C&R holders rather then spend time and effort going after them. Making up bogus violations to shut down gun shops shows their superiors that they are doing their job and deserve a bigger budget. But revoking C&R licenses or making it so people don’t want them would lose them money I think. Its not like a C&R license is really all that special anyway.
But, they’ve done crazier things…
What exactly are curio and relic licenses? How are they different from a standard FFL?
http://www.cruffler.com/
Basically it’s a restricted class of FFL that allows you to transfer firearms between other FFL holders that are more than 50 years old, or on the C&R FFL list published by the ATF.
Uh, the age of the FFl holder has nothing to do with it. It is the age of the firearm that is germane to the issue.
*grin* I might be missing a few commas in there.