LotsÂ ofÂ goodÂ adviceÂ out thereÂ on how to comment against ATF 41P, which will change the way NFA trusts work and generally make it impossible for many people to get NFA items like suppressors. I feel bad that I haven’t been harping on this issue, but as loathe as I am to be fatalistic, I don’t think there’s any stopping this. I certainly would never discourage anyone from writing, but I wouldn’t feel too bad if you didn’t get around to it.
They put this out for public comment because the Administrative Procedure Act (APA) requires them to do so. If an agency wants to change a regulation, Congress has prescribed a certain song and dance has to be gone through, including a public comment period. But they aren’t required to listen to any of it if they are intent on the change. The fix is in, in other words. The Administration intends to use this regulation change to punish us for thwarting his agenda. It’s one of those “elections have consequences” things.
And I’d note this will make it very difficult to ever get suppressors out from under the NFA, because it’ll mean fewer people have access to them, and with fewer people having access to them, there’s less of a constituency to drive political change. This will mean the first thing we probably need to drive for are either eliminating the LEO sign-off requirement through Congressional action, or passing more sign-off laws at the state level, like Tennessee has done.