One of Clients has submitted a comment to 41P and given us permission to post a copy as it is not likely that it will appear on the published comments before the time to respond has closed. You may want to use parts of this comment to help you express…
Below Summary of the issues covered in Attorney Glenn Bellamy’s 41P comments and exhibits: The Requirement of a local CLEO certification is not statutory in origin and exceeds the ATF’s statutory authority, making the proposed regulations vulnerable to attack. The regulatory requirement of a local CLEO certification imposes a discretionary…
In response to 41P we have asked others to send and inquiry to their local police to determine if ATF’s proposed changed to the CLEO signature would make a difference in the policy to provide or not to provide signatures on Form 1 or Form 4 applications. Below is the…
While many people will be waiting to the last-minute to file their comments to 41P, we felt that it was important to file something sooner to provide our clients and readers some guidance on preparing comments. We have created a webpage which contains our comments, exhibits, as well as a…
ATF is answering their phones and the electronic filing is back online at http://www.atfonline.gov. ATF reported today that they the payments are back online as of 10/22 but previously reported that they are having problems with the payments. In an email they reported: This is to advise that ATF eForms…
Last week many people in the industry met in Washington DC to discuss issues and concerns with 41P. Besides discussing what happened leading up to 41P, the main topic of discussion was regarding that 41P this was a legal issue within rulemaking and that inappropriate or inaccurate responses could cause…