Ryan thinks ATF could target C&R FFLs once they drive the number of type 01 and type 02 FFLs down to low enough levels. This is not out of the realm of possibility. If there’s one thing a government bureaucracy hates, it’s losing power, funding, and people. If it’s current mission can’t justify an agency that large, they will find new areas to focus on that’s within the scope of their powers.
The whole Curio and Relics licensing system has flown under the radar so far, but there is a very serious risk that could change.
UPDATE: Uncle thinks they will go after home builders first. I don’t disagree with this, but that doesn’t mean C&R FFL holders won’t get some attention too.  There are a lot of C&R FFL holders though, so to some degree we have the sea turtle defense. It’s worth noting that ATF didn’t harass “kitchen table” dealers out of business, they started requiring that the licensed premises be zoned properly for the operation of that type of business, which is a standard that most hobby dealers couldn’t meet. If you weren’t zoned, you weren’t getting your license renewed. Home builders can be gone after easily because they operate in a tricky legal area that prohibits “manufacture for sale” So if my buddy buys an 80% lower and asks me to drill a few holes using my jig and equipment, am I in the business of manufacturing and require a type 07 FFL? The C&R stuff is a lot more straight forward, but ATF can definitely make C&R not worth the hassle. C&R holders, what are the various ways you think ATF could make our lives miserable? It’s a good exercise. Leave your thoughts in the comments.