Letters to the ATF

Comments from our clients and others who will be affected by the proposed changes to the ATF will be important. Remember there is little to be gained by rushing to file comments or filing comments that do not raise an issue supported by facts.

Take some time to understand the proposed rule and understand how this may affect you and your family. You should discuss your views with your federal and state legislators and urge them to submit comments on how this will apply to FFL dealers, manufactures and citizens that they represent.

Your local dealers should submit comments on how this will impact their business.
You can discuss the new CLEO requirements with your CLEO and see if they would be willing to sign and if so what limitations they would place on obtaining a signature. Will they charge a fee like in Alaska, or refuse to sign as many CLEOs currently do because of the costs associated with the process.

Is it a cost issue, or will the CLEO not sign because they do not believe anyone has the right to own Title II firearms.

Any comments you submit should be supported by facts and not simply based on opinions.

If you have a gun trust with more than 2 responsible parties let them know and that their projections may be inaccurate because of their invalid assumptions over 2 responsible parties per trust. If you have 5, 10, or more let the ATF know.

It is important to be civil with your comments and avoid rhetoric that will distract from the points you are trying to get across.

We have previously posted a sample letter for individuals to use to express their experience with local CLEO signatures. You may download the FICG’s letter here

Below are some additional situations you may consider and if any of them fit your situation you may consider including them and the relevant facts in your letter to the ATF.

Some Additional Potential problems with New Responsible party and CLEO requirements.

What if my CLEO will not sign the new requirement because they have no way of knowing that the fingerprints are mine or that the photograph was taken within 1 year?
What if I get married and my CLEO will not allow my spouse to be added?
What if an elderly but competent parent moves into my house and needs to be added to protect from constructive possession and the CLEO will not sign?
What if my son is under age now but when he turn 21, I want to add him on my trust. The CLEO will not sign for him even though they are not a prohibited person and would pass all other requirements?
What if I add a friend to my trust as a responsible party so that we can go shooting together and am unable to get a CLEO for my friend within the 30 days as required?
What if my spouse is the military and deployed overseas when I want to make a purchase and a CLEO cannot be obtained?
What if a really large family that is located across several counties and states. Some CLEOs will sign but others will not. We keep the items on a family property where they are legal to own. Besides the cost of obtaining 10-20 CLEO signatures and fingerprints, how do we deal with the fact that some CLEOs will sign and others will not?
What if a Responsible Party is in a coma or otherwise physically incapacitated for an unknown time period when I want to make a purchase? Are they considered a responsible party and must I obtain a CLEO for them?
What if I have several Responsible persons who can obtain CLEO signatures but others who cannot.
What if my spouse or other co-trustee lives in a state where the items are not legal but will only be using them in states where they are legal and as such the CLEO will not sign because they are not legal in the state where the CLEO is sought?

Remember the importance of submitting comments which are based on facts.