I have lived in Virginia for most of my life, and it has been my “come home to” state for over 70 years. My father taught me gun safety when I was only 11, and I have many years of experience in honing those skills. I have lived in Virginia because it truly is the Commonwealth and represents a safe haven for all gun owners. Walking the woods across from my boyhood home with a box of .22s and Dad’s Winchester Model 67 was always a favorite pastime. 

I learned from an early age that if you liked your life and your lifestyle, it is critical to get off the chair and go vote for those who share your values. I have to say that I never gave gun control in Virginia a second thought, until recent years. I do shudder at the thought of what is happening in states like California, New York and Maryland. I do read about politicians pushing agendas that are baseless and grounded on not understanding shooting sports and the outdoor world, whether it is hunting, competition shooting, self-defense or just plain target practice. Like most of you, I read on a daily basis about the asinine proposals from these liberal-run states that unnecessarily burden law-abiding citizens and that have nothing to do with really reducing crime. 

When I was younger, I lived under the false belief that voting really didn’t make any difference, so why bother? Today I know and understand that voting is paramount to living a life unencumbered by politicians who simply don’t understand the law of cause and effect. If I want my agenda to be supported, I have to not only vote, but make my opinion count with others who would cast a vote. I really believe that.

There are many writers, like David Workman and John Crump, who have penned tremendous articles about the Commonwealth and many other states that are infringing upon our Second Amendment rights. There are many venues for strong voices to be heard, in print and online. And let’s not forget about the Virginia Citizens Defense League and the NRA who filled the Virginia House chambers with lobbyists and pushed inside the Capitol to fight bills such as HB961. They, too, kept us informed and fought a battle that most of us are ill-equipped to do. So how did we get here?

Frankly, too many Second Amendment enthusiasts only sat and read about what was happening. As quoted in AmmoLand, “… the result of a dismal turnout of only about 40 percent of the state’s registered voters” put us where we are today. The Democrats in the Legislature now control the votes. This is a sad circumstance. We have no one to blame but ourselves. If you don’t vote, you don’t have a voice, plain and simple. Yeah, I know, I hate politics the same as the next person. But the only avenue we have at making a difference is to exercise our rights and vote for those who represent our values and beliefs. 

If you take into consideration that the Commonwealth has somewhere between 1.5 to 2 million gun owners and only 40% of those owners got out and voted, it is no wonder we are in the situation we are in. How many of the 647,000 concealed carry permit holders in the Commonwealth actually voted? Less than half? The Virginia Legislature fell to the Democrats. I hear the story of the lion’s share of the voters in northern Virginia and Richmond controls the results, but I question the validity of that sentiment. There are a huge number of passionate Second Amendment residents in the rest of the state. Most chose to sit home and not vote.

In Virginia, the Republican presence with firearms owners is more than substantial. The problem is that most firearms owners don’t want to be bothered with the time and effort it takes to register to vote and cast their ballots. Those days should be over. We who did vote should be out there knocking on doors to get our “armchair cowboy” friends and neighbors off their hindquarters and out to the polls. I used to sit back and watch the news and say to myself, “I’m glad it’s not Virginia!” Well, guess what? The nightmare is real, and it happened in Virginia. The only way we can combat that is to vote for those who support the Second Amendment and our rights as gun owners. Get rid of those who would happily take away your rights, your guns and your ability to defend yourself.

I am personally asking that every gun owner across this great country of ours to get out of your armchair and go vote. As my dad used to say, “You have the easy part done; you’ve talked about it, now get off your butt and do something about it.” It is time for us to come together and vote as a solid community of 2A supporters. Hell, if the sheriffs from over 95 counties in the Commonwealth are willing to stand up for us, we better make sure we jump in front of that protective barrier instead of hiding behind it. Stand up and vote for all of our freedom in 2020. And remember to vote in EVERY election.

Please help us continue the efforts! Sign up or renew your membership today at nfatca.org/join.htm

. 

By John Brown

Changes in Leadership

During the last several months we have noticed many changes occurring within the leadership of ATF. The first announcement was the news that Arthur Herbert, Deputy Director, would be retiring at the end of 2014. That news had been heard before and we had our trepidations about that being true. However, it is official that Mr. Herbert is retiring and will be leaving after a long career in the Bureau. Candidly, our work with Mr. Herbert had not been met with the kind of cooperation that we had hoped. However, with patience, things eventually change. We just hope that the change is not worse than what we had.

As mentioned in an earlier article, many of us in the industry have noted some positive small changes in cooperation while working silently behind closed doors with those ATF personnel still friendly to the industry and who have been steadfast in their work with us. Now, in recent meetings both official and unofficial, it is a far cry from the days in this administration when ATF personnel were blatantly told not to even accept a bottle of water from industry members. Many of the cooperating personnel within ATF simply shrank back in the shadows and waited for things to change. Patience has its virtues and things are starting to pay off.

Early in the summer Marvin Richardson, soon to be Deputy Director, held a manufacturers meeting in Washington D.C. It was the first time in a very long time that all of the ATF staff and major industry members came together and genuinely smiled at one another. Credit goes to Mr. Richardson for pulling everyone together and discussing a multitude of regulatory issues that affect us all and all participants walked away from that meeting hoping for better times in cooperation.

Though we knew what was coming, we enjoyed much cooperation from ATF during this administration’s first term. It was of course in the second term that the storm started to brew and rain down a ton of anti-firearms legislation, targeted at manufacturers as well as the consumer. We have seen plenty of this during the first year and a half of the second term. Under White House direction it is no secret that the Justice Department has taken apart every idea from the industry and turned it against the consumer and the manufacturer. A simple idea of streamlining the Form 4 processes, by eliminating the Chief Law Enforcement signature, has turned into an absolute nightmare. The fear is that the more time that falls behind this type of legislation the less likely its impact.

Although the Justice Department has seen fit to forge its way into virtually every type of gun legislation, mid-term elections and dissatisfaction with the current administration are once again allowing a strong spirit of cooperation between ATF and the industry and consumers. A single example of this resides in the doubling of the staff tasked with processing forms for all types of NFA articles. Now at 9-10 months, with a target of six months, the Bureau in responding cooperatively with all of the trade associations and the consumers by adding appropriate staff to handle the load that is unprecedented in the history of the NFA. With a backlog of nearly 45,000 forms monthly at the NFA Branch, increasing staff is a natural and cooperative move to assist the consumer and the industry.

Changes in leadership at ATF will help at the Federal level and will once again give us the spirit of cooperation that we had enjoyed for so many years. With Marvin Richardson moving up, the dominoes start to fall and openings for more leadership positions will occur. Keeping a good relationship with ATF has always been a dictum of the NFATCA, and these changes will fuel our hopes of continued cooperation. That posture alone has been the reason why the NFATCA has enjoyed more cooperation from ATF than any other trade association in the firearms industry. We have stood steadfast for nearly twelve years and have withstood pain and agony of many types of proposed legislations. We have worked hard to support the industry and the consumer and have published the NFA Handbook and are nearly complete with the publication of the Firearms Technology Handbook. We will continue to keep our membership apprised of the latest news on all fronts.

The changes that we are seeing within ATF leadership are very positive. We have a lot of ground to recover and many things to yet accomplish. With a strong leadership within ATF and strong leadership within the NFATCA, we can and will accomplish our goals for the future.

Come join the NFATCA today and become a member of a powerful team that works for you, the industry, the consumer, and the sportsman, in defending not only our Second Amendment rights but for your NFA rights nationwide.

Doing the Right Thing

The past year for the gun community has been one of turmoil and confusion. From history and experience we have seen that presidents don’t touch firearms control until after their first term. Welcome to this administration’s second term of turmoil.

The one major factor that we as a community are missing is solidarity. Many of the largest organizations are failing to understand that working together to fend off firearms legislation has now come to a critical point. Not only are all of us working tirelessly to fend off issues such as 41P, but we now have to turn our attention to the states to fend off firearms legislation that is being fueled at the state level. There is so much confusion at that level that enforcement agencies don’t even understand the legislation and, worse, don’t know how to enforce the new regulations. Confusion on issues such as whether a firearm is banned or not to figuring out how to enforce magazine ban alerts has many state enforcement personnel calling ATF for clarification. It is a chaotic mess particularly focused in as many as thirteen states in the Northeastern part of the country.

What does this mean? It means that there is opportunity for the industry to get involved and stave off further legislation with the real facts on each of these issues. Organizations such as the NRA, Fair Trade, The American Silencer Association, and certainly the NFATCA, are at the forefront of figuring out “How do we work together and place our time, resources and money towards a common goal while defending the Second Amendment.” In a time when the next generation is even questioning the value of the Constitution, it now more important than ever that we work alongside of each other to better position our resources to move things in a more sensible direction.

In late May of this year some of the top leaders in the industry were meeting privately to discuss critical issues and figure out how we improve the leadership in this country and support those individuals in the fall elections that believe in our Constitution and support the rights that we as U.S. citizens have elected our U.S. officials to uphold and support.

Our country is in jeopardy financially and from the very infrastructure that had hard working men and women build what we have. The thought of entitlements going far beyond things like social security and your retirement are becoming the new trend of the new generation. People all around you support “Change” as if it meant getting more stuff for free. As you know, or should know, nothing is free – someone has to pay at some point.

This private meeting had one objective in mind; build a better America through better leadership that will likely start in the U.S. Senate. Our problem has consistently erupted into a society that says, “I want the government to take more control.” In reality, that track record speaks for itself with one failed example after another in a long list failures. It just doesn’t work.

As we now know since Congress was unsuccessful at passing a new Assault Weapons Ban, this administration turned to the states and simply asked for help. The result has been catastrophic and will continue to run a slippery slope unless we put the right people in office to do the right thing, protect the Constitution. Managing that process and at the forefront of this battle are our elected leaders nationwide. Who elects those officials and the platforms they represent is up to you the voter.

There was a time when I said, “It can’t get any worse”, that is, until I saw a bumper sticker in early May that read, “I’m ready for Hillary.” The States and the Feds are mixing the Kool-aid again and it is time we vote together and make the kind of change that we as firearms owners want. There is an entire generation of Americans emerging that have been drinking this Kool-aid and need to know the truth. As mothers and fathers, brothers and sisters, that is our responsibility to teach them what America is all about.

Do your part in building a better society with our young people so that they too can understand the meaning of debt and the change that will make it impossible for anyone else to pay for that debt except them. Teach them that strong seasoned leadership insures better results for success and the future of our economy and our country as a world leader.

Building a country on debt that exceeds your assets will certainly lead to failure. And you may ask yourselves, who will pick up the pieces?

In the meantime I will get off my pedestal and give you some news that has a more positive note.

ATF NFA Branch has hired 15 new examiners that are in training as we write this article. That additional workforce will have significant impact on our NFA transfer times so we can reduce the amount of time to get a transfer approved from ten months to less than 90 days. With more than 72,000 transfers in the backlog this month this will take some time to make a difference, however, there is a light at the end of the tunnel.

On another note, 41P has now been delayed to January of 2015. I can only say thank Heaven and hope that the over 9,000 response to this bill will delay things even longer than next year. The pressure of the fall elections will certainly impact what happens here. From the over 1,000 members of the NFATCA we say thank you for taking the time and energy for making your voices heard.

As a last note you should all know that we will soon see new leadership at the NFA Branch which should have a major effect on processes within the Branch. We will keep you posted on who will fill this new position. In the meantime the entire industry takes it hat off to Ted Clutter, who tirelessly serves the NFA.

As mentioned earlier, the leaders of some of the major firearms organizations met and discussed a common strategy to defeat the multiple attempts at gutting the Constitution. At the forefront of that meeting were discussions on electing officials that support your rights as Americans. It is truly time to support those of us that are fighting for you and to get out and vote for the kind of leadership that will get us back on track with our Constitutional rights.

We simply ask for your support and your getting out and voting this fall for a firearms friendly leadership that helps us manage our future.

Thank you.

Healthcare.gov 2.0

“If you like your old plan, you keep it. Nobody’s going to take it away from you.” Does this sound familiar? It should because a government plan to fix what many in government widely perceived as a broken system was implemented with the proviso that you absolutely could keep what you were already comfortable with using to take care of “business.” Except that all of the new stuff that was put in place to make the new system work actually did have a negative effect upon the old plans. Many of the old plans did not meet the requirements of new rules and regulations. Not all of the old plans were quite up to snuff and even though the President said that you could keep them, that pledge turned out to be ever so much political speak for, “you’re gonna do it our way.” Pay no attention to the fact that “our way” involves a system that was poorly constructed by contractors who failed to utilize expected norms of modern technology and techniques, operation, security and usability. Ignore the fact that “our way” is regularly unavailable for even routine use. Walk past the ongoing issues of the system regularly being unable to access needed information or display it for proper use. Discount the fact that only a small fraction of the user base is able to consistently use the system for its intended purpose. Now add in the instructions from the Fed that you are encouraged to use the system, as is, and submit your information with known errors and then submit a written request to have the already overburdened staffers go back and correct mistakes after the fact. And to add to the delicious cauldron of government goodness, you are informed that all submissions to the new system absolutely will receive preferential treatment as compared to “your old plan.” The infrastructure system of ObamaCare known as www.HealthCare.gov sounds pretty shaky, as does the government’s insistence on sticking with it, no matter what.

Except that we are not discussing www.HealthCare.gov or ObamaCare. We are talking about the Department of Justice – Bureau of Alcohol Tobacco Firearms and Explosives’ contribution toward government efficiency and progress that is better known as eForms. Sadly, the parallels that can be drawn between eForms and HealthCare.gov are eerily similar:

The eForms system design was created by a contractor organization that:

• Did not implement current technology
• Did not understand the scope of the project
• Did not complete the initial project

The eForms system was not thoroughly tested before launch to:

• Validate access compatibility with current, commonly used browsers (recommended browsers are not current or even shipped with current computers)
• Verify stability under load Confirm functionality of registration process
• Assure accurate data integration
• Provide reasonable error correction
• The eForms system must be taken down and restarted most every day; some restarts taking longer than others
• The eForms system is subject to intermittent stalls
• The eForms system frequently fails to load system sub-components, even after successful log on
• The eForms system requires that users force the propagation of known descriptive errors (manufacturer, model, serial, etc.)
• The eForms system does not support the attachment of fingerprints or photographs (rendering the ability to tackle the largest backlog of NFA Form approvals moot)
• The eForms system does not clearly explain what the approval process will look like and does not inform the user of the validity and acceptability of the “new stamp” process
• The eForms system does not have plans or budget in place to address the known issues
• The eForms system is faced with additional issues that are labeled as “we don’t know why this is happening”
• The replacement contractor has finished their work under the current contract and there is no additional contract being bid at this time
• The NFA Branch is informing users, when asked, that eForms applications absolutely will be given priority over traditional paper or facsimile submissions, despite the known issues
• NFA Branch has been made aware of the fact that the eForms system does not accurately reflect dashes and spaces in serial numbers, as required by ATF communication to industry via written communication and Webinars. This has the potential to cause problems during compliance inspections when an IOI does not fully understand the system limitations

To recap, the firearms community is being rather demandingly herded into using a system that is incomplete, inaccurate and just plain not ready for prime time. And even though all of the involved parties are painfully aware of the shortcomings of the preferred system, there is no plan or budget for the foreseeable future to address those shortcomings. Despite all of this, our community is trying its best to accommodate what most would consider to be a less than stellar situation.

According to the 2013 Firearms Commerce in the United States Annual Statistical Update (published by BATF), the NFA community, which is the primary target audience for eForms, has swollen the government coffers in terms of monies paid over the past decade. Total annual revenue collected by NFA Branch in terms of Occupational Tax paid and Transfer and Making tax paid has swollen nearly 300% from approximately $5.6mm in 2006 to approximately $15.5mm. The increase from 2011 to 2012 (the most current data published in the Update) is nearly 25% and there is no reason to expect anything but another huge jump in revenue from 2012 to 2013. If there are currently 21 agency folks assigned to pushing NFA “paper” (12 Examiners, 7 Specialists and 2 Supervisors), the allocated rate of cash intake per assigned personnel comes in at almost three quarters of a million dollars per desk. A glaring question comes to mind: At this income level, why can’t we get more personnel and a functioning electronic system that will actually support their efforts? There is more than enough money to fund the enterprise to the point where it could effectively and efficiently tackle the current work load and accommodate increases for many years to come. People are willing to pay for reasonable service People are not willing to embrace ever-increasing wait times, balky systems and processes that perpetuate errors and mistakes. Yet that is exactly what we have in the form of www.HealthCare.gov 2.0… otherwise known as eForms.

Those of us who submit official forms to ATF that are included in the eForms system must embrace the new reality in a manner similar to those seeking health care coverage under the government’s mandated system. Yes, you can use the old paper system if you are more comfortable with it. But your old system has changed in that it is absolutely going to take a back seat to the new eForms systems – the eForms system that is acknowledged by ATF officials as substandard. The eForms system that may or may not be available when you need it, that may or may not allow you to access it with your own current computer hardware and software technology, that may or may not be able to accurately reflect items that you are trying to transfer and that may or may not display or print information correctly. If you choose to use the eForms system, make sure that you have a healthy serving of patience by your side. If the system “insists” that you complete a form that you know has errors on it, please forward a copy of the approved form, a detailed explanation of the error and a request for acknowledgement to:

BATF
NFA Branch Chief
244 Needy Rd
Martinsburg WV 25405

You are absolutely encouraged to begin using the eForms system right now so that you can become familiar with its functionality and abilities. ATF sends out a helpful hints guide after you register, but you may wish to review the guide before you register. An electronic copy can be found at www.nfatca.org/pubs/eFormsHints.pdf. If you have specific questions regarding the eForms program you may contact Gary Schaible (gary.schaible@atf.gov, 202.648.7165) or Lee Alston-Williams (lee.alston-williams@atf.gov, 202.648.7166).

What is Happening to NFA Trust and Corporate Transfers?

Many of you are aware of the circumstances where our work was manipulated and turned against us in our effort to rid the industry of an archaic process requiring the Chief Law Enforcement signature on securing the transfer of any NFA item on Forms 1, 4 and 5. Our work and negotiations were turned against us and manipulated into requirements that were never on the table for negotiation.

The introduction of the notice of proposed rule-making (NPRM) in 41P was a turning point in this administration’s effort to enforce unnecessary controls in the NFA world that will neither increase or improve any results in public safety; a key objective of the Bureau of Alcohol, Tobacco, Firearms, and Explosives (BATFE).

Through numerous meetings, and having reached an agreement to rid the NFA industry of the CLEO signature, the Department of Justice, under this administration, decided to take unexpected measures to harm the industry. An idea to appoint a responsible person under a trust or a corporate entity turned into requirements that would damage, beyond repair, a simple concept that would insure that entities would have one responsible person to insure that prohibited persons could not be protected under the guise of the entity. That being said it is simple to understand that our original concept was bushwhacked and turned into a nightmare by the administration’s efforts.

Thankfully over nine thousand of our loyal supporters took the time and made the effort to submit great arguments against 41P and explain to the Federal Government that this effort would accomplish nothing to insure public safety. Organizations such as the NRA, the NSSF, and ASA submitted strong evidence and arguments against the deployment of such a useless NPRM. The tremendous response has now delayed any response or implementation of 41P until June. What has to happen now is a responsibility that every NFA owner must take on to further fight this onslaught of further government control.

All of us must now reach out to our Congressional representatives to further strengthen our position of opposition to 41P. In many of the responses that were submitted one factor was clear: the deployment of 41P would serve absolutely no useful purpose and is impossible to deploy. The most important factor that has been brought to DOJ’s attention is the almost immeasurable cost of such a ruling. Additionally, it would nearly kill the NFA industry and the many stories of success for small businesses. The impact on small business is a fact that can’t be ignored. In a stagnant economy this type of ruling and its impact on small business is a major consideration; especially to government agencies like the Small Business Administration who are struggling to keep small business strong in support of the economy.

With over nine thousand responses one would think that this would make a major impression on DOJ. The simple truth is our responses are not enough. Every one of us must make plans to contact Congressional and Senatorial personnel and make the case that 41P will not work. The NFATCA’s plans include working closely with the NRA and other organizations and contacting these personnel, making our case, and having these personnel support our cause at the Congressional level. This follows the lines of contacting firearm friendly Democrats and Republicans. Once we make these contacts, we will support these personnel at making this case for denying the approval of 41P at the highest levels in government. Securing this level of support and making demands on defining the costs and impacts on such a ruling will enforce the lack of credibility of 41P. It is critical that you arm yourself with the facts that are available on our web site as well as those supported by the American Silencer Association and other powerful organizations like the NRA or the NSSF.

Getting this accomplished will require not just the efforts of the NFATCA or the NRA but every member of these organizations on an individual basis. If all 1,000 members of the NFATCA or just 10% of the NRA membership sought the support of a Congressional representative, the “push back” would be phenomenal. That initiative requires action and a sense of intention like we have never seen in the NFA industry. Once again I will remind you that, “United We Stand, Divided We Fall.”

Regardless of what you have read or believe, it is time to put aside your differences and fight for protecting all of our NFA rights.

The NFATCA stands for all NFA owners’ rights and we will fight to do whatever it takes to win this initiative. Whether you are one of our 1,000 members or you enjoy membership in another organization that better suits your needs, this is an issue we must all fight together. Put aside your differences and understand that we all have one objective in mind; “To protect the NFA industry” from government intervention that does nothing for public safety.

This initiative will require you to take the time to write, go and meet with your Congressman and help them understand the uselessness of 41P. It’s time to not sit back and participate in another blog slandering the efforts of the NFATCA or an individual. It is time for you to stand up for what you believe in and make a difference with muscle that you voted for. Contact your congressman today and help us take on this initiative with the strength and the support that we all need. Join the fight today in support of all NFA owners.

(www.nfatca.org)

What is Happening to NFA Trust and Corporate Transfers?

If you are reading this article you will likely have been tracking the latest debacle from the White House that is, for whatever reason, being blamed by some on the NFATCA. In 2009 we did in fact submit a petition to ATF, after many meetings with our membership, to make recommendations on several fronts. Primarily was a submission to ATF to eliminate the painful process of having to have the CLEO sign off on Forms 4 and 1 – a process we had been working on with ATF for years. It is common knowledge that the primary reason why trust and corporate transfers had escalated so dramatically over the years was simply because many local law enforcement agencies would not sign off on a Form 4 or Form 1.

The only alternative to that process was to build a trust or start a corporation and handle the transfer with a legal entity. As we openly discussed many times, the only flaw in that process was the lack of any background check. When this process first started, not even a NICS check was required. Everyone in our community was worried that it would only take one single incident of the wrong person initiating a legal entity to acquire an NFA item when legally they would possibly be personally prohibited due to a criminal record in their past or for some other legitimate reason. We all knew that it would only take one person, that had no background check or no NICS check that was in fact a prohibited person, to be able to acquire or have easy access to a NFA weapon, to upset the entire apple cart.

This type of catastrophic event could easily take on a life all of its own in regulatory issues. Our objective was to propose a means by which this looming disaster could be avoided and work with ATF on a simple solution. Our suggestion was uncomplicated and straight forward:

First, eliminate the cause of this problem of the huge increase in trust and corporation entities by eliminating the need for the CLEO signature. That issue was suggested and worked towards ten years ago by the NFATCA.

Secondly, since ATF was going to act on this anyway, we recommended that regardless of the legal entity, a responsible person should represent the trust or corporation. This is an easy process that would allow any entity transfer to have a responsible person that could be designated to represent the entity and to submit fingerprints and photos. This process could closely parallel the process now in place with any FFL. Even a corporation must have a responsible person. A reasonable request.

From that point in our discussions with ATF nothing happened after the election five years ago; and ATF took on a noticeably different demeanor with the industry. No surprises here as we had been there before under another president and party years ago. But this time was different – things got quiet and often phones calls previously accepted were ignored. In protecting itself, ATF personnel sat quietly to see what direction the administration would actually take.

The first sign of real trouble occurred when the White House lost the first round of major gun legislation in congress. While everyone was celebrating, unfortunately, a lot of us sat down that afternoon and said, “Here it comes.” The current administration does not like to lose and as the president railed on his political loss in the Rose Garden, it was obvious that he intended to unleash his dogs in any way he could that included presidential dictates, using the vice president as a point man, cabinet policy hindrances, and blue state governors, senators and city mayors were all encouraged to act unilaterally. Additionally, the government regulatory agencies that are charged with protecting, promoting, regulating, supervising and enforcement now turned noticeably adversarial to our industry. Make no mistake: ALL of our firearm freedoms are under attack.

When you look at the statistics within ATF, one of the glaring factors is the tremendous rise in NFA transfers through corporate or trust entities. The backlog of transfers is in the tens of thousands and ATF is now advising a transfer time of up to 15 months. Those statistics alone made ATF and the White House target this obvious and conspicuous issue. Given the fact that there were minimal background checks resulting from ambiguous and confusing guidance on the 40,000 plus entity transfers to date at that time, it was apparent this was an easy target. The rest is history.

If you think for one moment that the NFATCA stands by the Notice of Proposed Rule Making by the White House, you are sadly mistaken and wrong. We fought to help manage this process in light of getting rid of the CLEO signature. Our necessary petition aligned itself with measures of forcing ATF to come back to the table and work with the industry. The White House saw an opportunity and took it.

Finally, as usual, a lot of backseat drivers and anonymous keyboard cowboys came out of the woodwork accusing the NFATCA as being traitors to the Class 3 community with one idiot actually threatening my life as well as one of our board members. These disruptive people, who hide behind their computers, are more than willing to throw anyone and any organizations under the bus if they don’t adhere to their extreme views exactly. Their sole purpose is to embarrass and poke the government and advocate the abolishment of the 1934 GCA and all subsequent laws and, while they are at it, eliminate all income tax. Nice idea but it ain’t ever gonna happen. The NFATCA has been around coming up to ten years in this industry, yet the naysayers would prefer to sit on the sidelines and criticize the plays and mock the coach, while absolutely making no contribution, constructive or otherwise, to the cause. Additionally, these same people think we work in secret with diabolical plans in cahoots with the government. Our actions are no secret and never have been. We have made public notice to our intentions via regularly appearing articles in Small Arms Review magazine, the SAR Show public meetings in Phoenix and York, the Knob Creek Shoot public meetings in Knob Creek twice a year, plus our presence via information booths at the SHOT Show in Las Vegas, and Orlando, the NRA Annual convention in whatever hosting city, and via our newsletter. There is no secret agenda and we have clearly communicated our intentions on the issues and we have received support from everyone at these meetings.

In these very trying times for our community, it is lunacy to think that these anonymous naysayers who criticize and mock on the internet are people acting in a positive manner. I know that what we are doing is good for the community – the dealers, the manufacturers, the importers, the exporters and the collectors – and we will continue all our efforts to be the voice to protect their interests. We have joined hands with those that are willing to work alongside us and in unity that include some of the biggest names in all areas of our industry. Why it is more important to stand outside and criticize than to join in and handle this administration as a united bloc is beyond me. Now is not the time to listen to deconstructionists. I recognize that we will not always agree on everything but I do know that in these very trying political times it must be a united effort against a larger enemy. I will forever stand by the mantra that we have called on for a long time: “United We Stand, Divided We Fall.” Sitting on the sidelines letting others do your bidding and hoping for change is past. It is time you joined our fight. Find out more at www.NFATCA.org.

For quite some time now, everyone that shoots has been complaining about the shortage and, the pricing, of ammo all across the country. All you have to do is visit your local Wal-Mart to see and feel the problem. A recent trip to a local Wal-Mart that was visited a few weeks back and the issue was still the same. Other than all of the new Turkey loads, there was nothing in the glass case with the exception of cartridges for hunting rifles that were questionable for large game applications or a modern day firearm. When the store clerk was asked when he would be getting more .22 long rifle, he laughed and shrugged his shoulders. He looked at me and said, “Sir, this has been the situation for a long time now. Even though I limit customers to three boxes each, they still send their entire family in to buy what they think they need.” And so goes the situation in not only the Wal-Marts of the world but virtually every place that we all used to buy our ammo. Based on all the hoopla and speculation about this issue from some mysterious guy that was wearing a tinfoil hat, it is almost impossible to know who to believe ranging from DHS (Department of Homeland Security) buying 1.2 billion rounds of ammo, to “The government is buying it all up so we can’t get any.” Regardless of the “Mall Ninja” and Internet hoopla, the problem is real and is worthy of a bit of investigation.

First, let’s take on the Homeland Security issue. It is true that DHS has put out several procurements for large amounts of ammunition. The only thing that is alarming about procurements this large is the fact that few of us realized that DHS has grown to this magnitude. Realizing that they have, and figuring how much ammunition it takes to keep a DHS agent tuned up, that amount of ammo is not surprising. In fact it is a good thing that we have not looked across the board from all governments agencies. If we knew that number, I am certain that someone would pass out. With nearly 30 Federal Agencies operating independently, the ammo requirement for an organization this large would be mind-boggling. Keep in mind that DHS is simply one of these thirty agencies. But hold on! Has this not been the situation for many years now? As a matter of fact, yes it is, and will probably continue to grow with “Big Government.” Let’s also keep in mind that most of these agencies have been on the continued increase in government awareness for security for at least ten years now. As government grows, training increases and ammo depletion rises. But wait, there’s more.

Let’s take into consideration the rise of the AR rifle platform in the U.S. In 2013, there are over fifty AR manufacturers in this country churning out more product than you could possibly imagine. The average AR manufacturer is making, let’s say, an average of 2,500 rifles this year. That number is much lower than what is actually being manufactured but, remember, we are trying to get to the bottom of this ammo shortage with a realistic look at what is happening. With the current backlog in major manufacturers, that number is likely closer to 500,000 new production AR rifles hitting the market this year. Let’s pretend that each person buying one of those rifles fires 100 rounds from that gun the first year. Just on this side of the equation we now have a requirement for over 50 million rounds of just 5.56mm ammo, and please keep in mind, this is one gun in one caliber. Take into consideration that with that type of civilian requirement, it is not too hard to imagine, just what ammunition consumption is starting to look like. Getting to a billion rounds a year is an easy yet daunting task, once you take into consideration that this is only one example of consumption with one caliber. Take into account the numbers of rounds consumed by other calibers, like 9mm, .40 and .45 ACP, things really start to heat up in the consumption department.

It is no secret that government agencies are acquiring much more ammo. Basic requests for pricing and proposals call for ten-year supply quotes, where historically quotes were made for two year purchases. This drives the dollars spent and the numbers required way beyond what we are used to seeing.

Take into consideration what we read everyday about government consumption and increases in the threat of gun control; the natural reaction is to stock up. If you don’t believe this, then visit your local gun show and see inside where the line starts. It is always at the ammo tables where, regardless of the price, people are scarfing up ammo like gold.

When a major newspaper like the Washington Times prints the following: “Bullets are easy to store, non-perishable, and they hold their value or even increase in times of crisis…” it just makes sense that even the lonely little .22 long rifle cartridges are being bought up like candy.

If you consider the following:

• One of this administrations primary objectives is to increase gun control;
• Sales of firearms are at an all time high in the nation as a result of political pressure;
• Panic buying on firearms is soon followed by buying ammunition for the guns of our choice;
• Rumors abound that ammunition could be the currency of the future, and
• Rumors on all kinds of requirements to buy ammo from taxing to permitting just make it impossible not to go out and buy everything you can get your hands on.

It is only natural that panic buying and hoarding of current production is in the making. Simply stated, we have become our own worst enemy when it comes to the supply that is meeting only the demands of a buying community from 10 years ago. It is no wonder that the shelves are empty. Sales have increased at a phenomenal rate and the supply chain has remained at the status quo.

Major suppliers such as ATK, Winchester, and Remington, to name a few, have been stepping up production by buying new equipment, running multiple shifts and doing everything possible, to meet the increasing demand. The bottom line is that the more the manufacturers make, the more the buyers are willing to stockpile. The sad truth of the matter is that even law enforcement is having trouble fulfilling the ammunition necessary to qualify officers. This particular problem is not brought on by any one source but a multitude of factors, which combined have a dramatic effect on supplies.

If you have convinced yourself that DHS is hoarding ammo, you simply are not looking at the big picture. You are, however, not alone in your concerns.

In May, two Republican lawmakers, Sen. Jim Inhofe and Rep. Frank Lucas, of Oklahoma introduced legislation that requires audits on the impact of government ammunition purchases on the U.S. market. This legislation would limit the U.S. government’s ammo stockpile to six months supply, rather than the current two years worth stored in federal armories.

What a mess! The bottom line is you still can’t get what you need. My advice is to give it every effort not to hoard ammunition when you have what you need. If both commercial and the federal resources would work together to pace the procurement of all ammunition then manufacturers would get the breathing room they prefer to catch up with the current demand. That will require a cooperative effort on all of our parts. That’s our two cents on what is causing the demand, and how cooperatively we can all work together to fix the shortage. Do your part to work together to bring this fervor under control for all concerned.

If you want to really make a difference come and join us at www.NFATCA.org and help make a difference.

Gun Control Galore

Many of you have noticed in the past year that between the many promotions and movement of personnel at ATF that we sometimes seem to have lost that invaluable connection with those personnel at ATF whose relationship with our organization has been invaluable. Between a lot of phone calls and face-to-face meetings, a lot of things that we have been working diligently to get accomplished are taking on a new light with the spirit of cooperation we have not seen in quite some time. Like any large organization, ATF suffers from resource movement and the consequent re-establishment of relations to personnel that make the going easier. We would like to highlight some of the many issues that we have been working, in some cases, on a daily basis.

First and foremost is the CLEO signature. Although the wheels of justice turn ever so slowly, this mission is on track. The critical nature of this change has required everyone from the Department of Justice to the Office of Management and Budget to get involved in looking at every angle that is impacted by this change. Keep in mind the CLEO signature was first put into effect because in many cases the CLEO was the only person that could check on the persons purchasing an NFA weapon and vouch for your background. Originally, there were no instant background checks available. Historically, the wording on your Form 4 and the language was intended for the CLEO to actually vouch for you personally. The form four reads: “I certify that I am the chief law enforcement officer of the organization named below having jurisdiction in the area of residence _______name of trasferee________. I have no information indicating that the transferee will use the firearm or device described on this application for other than lawful purposes. I have no information that the receipt or possession of the firearm or device described in item 4 would be place the transferee in violation of State or local law.”

The CLEO was vouching for your good character, after running his or her own local background check. Regrettably, this statement became an Approve / Disapprove point of contention. In many instances the CLEO would not sign, as if disapproving your Form 4. Among other reasons, the CLEO did not want to take on the liability of you owning such an article.

The result was the use of corporate transfers or using an NFA or Living Trust to circumvent the entire CLEO debacle. As a result, several prohibited persons slipped through the cracks and acquired NFA articles by circumventing the CLEO. We all know and understand that this is not the intent of a Corporation or the objective behind a Trust. Nevertheless, these “prohibited persons” acquired their items, damaging the use of both legal instruments. At this point we know that if you give anyone the tiniest loophole someone will eventually use it to harm the majority. This in itself has led ATF to slow the elimination of CLEO signature process and to look closely at how this can be done and still maintain a good solid process that checks out the backgrounds on all Form 4s. We know that there will be changes to our original requests but at this point we do not know the details on how this will appear. We do know that the CLEO signature will disappear; we just don’t know the final result. It has been three years in the making but we are making progress through the ranks with many personnel at ATF who are diligently working with us to get that completed. Nothing good comes easy and this is a prime example. This program is a hot topic with our work at ATF today and continues to draw the attention of many of our friends within the Bureau.

Next up on the agenda is our work on both the NFA Handbook and the Firearms Technology Branch (FTB) Handbook. We have prepared major revisions to the NFA Handbook and at this writing are preparing those updates to work with a select team of ATF employees who will help us complete this program in 2013. Plans are currently underway to finalize these revisions by spring. We will keep you updated on all of our progress.

The next major undertaking was to define and produce a Firearms Technology Branch (FTB) handbook teaming with select personnel from the industry and ATF. The first draft of that handbook has been produced and has been on hold with a changing of the guard at ATF. With Earl Griffith as the new Branch Chief, Earl is working to review the draft and to determine the best path forward. The objective of this review is to get this critical information into the hands of the industry to streamline how anyone in the firearms industry can better understand the regulations and learn from the hundreds of pages of information. We are jointly determining how to keep on the right side of regulatory issues from large manufacturers to an individual who wants to make something themselves. We all know and understand that with the thousands of rulings and regulations involved in this process that this was a daunting task. Take into consideration that the draft is already in excess of 300 pages, this has been a challenge for both the industry and ATF. The new Branch Chief will examine what has been prepared thus far and what needs to happen to produce a useful document for both ATF and the industry. At the conclusion of that process we should be able to jointly tell you what is left and what needs to happen to conclude this process. That, too, we expect to finalize sometime in the spring of 2013.

In addition to the documentation programs underway, the NFATCA are working closely together to help ATF to get even closer to the industry. This will take place in 2013 on many fronts. We will first of all work to have the right people be present for all of the major events that will take place this year. We continue to have guests at Knob Creek and to extend the capability of ATF’s availability by offering tables at the major events. Staffed by examiners and other ATF management personnel from the local field offices, to executives from Martinsburg and Washington D.C., ATF will continue to be present and available for all of the questions and issues that face the industry. With the current political environment this will be especially helpful to help better understand regulatory issues and their interpretation. This could prove to be one of the most information packed years in the history of the NFA. We would like to take this opportunity to thank ATF in helping all of us get closer to all of those issues that we face on a daily basis.

Lastly, and certainly not least, the NFATCA will be hosting the NFATCA Expo in June of this year at the NRA Headquarters in Fairfax, Virginia. This event is intended to offer an abundance of topics that will be of interest to any NFA enthusiast. Please check our website for more details and make your reservations early. The topics and guest speakers will be exciting, topped off by tours of the NRA museum and its fine NFA collection. Attendance to this event will be limited so don’t delay in making your reservations.

It is proving to be an exciting year with the kind of help you can only get from the NFATCA. If you are not among the 1,000 members with us today you are surely missing out. Come visit us today and join in, in supporting one of the fastest growing organizations looking after your rights. You can do that today by visiting www.nfatca.org.

By John Brown

At the writing of this article the candidates are running neck and neck for the Commander in Chief, the President of the United States of America. No matter what direction you explore, the backgrounds of these two gentlemen concerning the future of the gun industry is not looking good. If you take a look at the last four years of our President it looks and feels like ATF is winding up for the second four year term of tighter controls and less of an ear to what anyone in the industry wants. Many of us are calling this the calm before the storm in many ways. If Obama wins the election we will have an unleashing of the full wrath of the Justice Department and the few remaining friends that the industry has built in the last ten years will certainly take a back seat to stay out of harms way. I can’t say that I blame them for running out the rest of their time and staying below the radar screen. These are troubling times to say the least.

If you go back and take a look at both candidates’ records, we are certainly way off course for the kind of care sportsman and gun enthusiasts received under a Roosevelt or a Reagan administration. All of the major support organizations that are working hard to protect your rights are working around the clock to keep a close watch on every seat in congress. Every day we are watching all aspects of the behavior that we see coming from congress and ATF. What you have to watch on the ATF front are the continuous flow of decisions now in the form of letters that sneak underneath the radar and then pose themselves as forthcoming regulations. We all know if a letter has already been sent to someone out there with a conclusion, it’s almost certainly too late to do anything about it. I look at the letters that are sent to individuals and I have to shake my head in disbelief. First and foremost I often wonder why in the world someone would even ask a question like that, and secondly when the answer comes to the individual, it is almost certainly an “OMG.” Oh My Gosh, I can’t believe that we are now stuck with that opinion. Careful what you ask, you may be astounded by the answer.

There are dozens of other channels that are available to you to get answers that you need and it won’t come to you in a letter that will soon end a privilege that you once had. Our Rights are under enough attack without whittling down the regulatory “Privileges” we seem to live with today.

With whatever candidate that is coming to us in 2013 you have to ask yourself the question, “What is the best venue for me to make certain that I have good representation on the hill?” With 2013 in the wind you better believe that if you want your money to work for you it will gain the most interest in one the organizations that best supports your interests. No matter if Title One firearms is your hobby, where the NRA is at its best, or you are in importer/exporter and the F.A.I.R. Trade Group best serves your needs, or it’s supporting the NFA industry and community and you want to give your support to the NFATCA, you will soon need to pick one and give it your best efforts. No matter which candidate ends up in the oval office the track record and what each of the candidates want, it is not to continue to let you and me to buy “Assault Rifles” and the like. Putting a permanent assault weapons ban in place and taking on this portion of the industry has been a primary objective of not only the Democrats in this country but a larger part of the liberal party line. There is only one reason why so many people are buying so furiously today; they are deathly afraid that they won’t be able to buy it again, in the next four years. The truth of the matter is no matter who is in the White House; both candidates have a history of staunch gun control. It is a great time to buy.

No matter what you collect or what you buy, there is an organization designed specifically for your needs to protect your rights. As each day passes, put yourself in a smart position and join an organization that will protect your rights and have the time and the funds to stand up for you at every angle, no matter who is in the White House.

We at the NFATCA will be there for you today and the day after and each and every day after that, looking out for your NFA rights. We will be reaching into our 9th year supporting the NFA community and our numbers continue to grow and our board members continue to grow more powerful in supporting you.

No matter how difficult times may get in the communication game with ATF you can bet on one thing for certain: We will continue to listen to our membership and provide you with a support that is unique, only because we believe that working closely within the ranks of ATF is the only way to enjoy success. Believe it or not a lot of our brethren at ATF enjoy shooting as much as any one of our members. Working together and better understanding one another’s needs is paramount to our continued success under either candidate. It was with continued cooperation and working together that we are able to produce the NFA Handbook, and the Firearms Technology Handbook. If you think anyone could put together such resources without working closely with ATF, you are dreaming. Having and keeping a good relationship internally is more important today than ever, regardless of who is in the White House. The method that we have always used in our eight-year history is “Power Through Experience.”

So for whatever administration we must endure over the next four years, make certain that you support the NFATCA or whatever organization you feel will best benefit from your financial and personal commitment. We are all working to protect all of our best interests in supporting the 2nd amendment. For more information contact us at www.nfatca.org.

By John Brown

In this third installment of the ATF Weight Loss Plan, we will explore the final portion of an NFA inspection: the NFA portion of your inventory. Our objective is to help alleviate the fears of an ATF compliance inspection by providing you with enough information so that you are well prepared for an inspection.

One of the final things that your inspection will entail will be the thorough review of your NFA inventory. This may be the most painful portion of your inspections through no fault of your own. The inspector will bring a printout of your inventory that is a printout of the National Firearms Registry and Transfer Record (NFRTR) that details the serial numbers of your NFA inventory. That’s right, the serial number. If you were to have to locate anything in your inventory strictly by the serial number you may want to assess how you would find anything in your inventory.

The registry focuses on the serial number of your NFA items and the other information that may help you identify that item in many cases is difficult to decipher from the information that is located on the printout. It is my suggestion that if you have a significant inventory, you list those serial numbers in a way that allows you to search for the number. For example, a simple Excel spreadsheet will allow you to quickly and efficiently find a serial number and retrieve the necessary information that you need to retrieve the weapon for the inspector. Finding the serial number and retrieving the weapon will make your inspection go much faster. If you are using any of the software systems that keep track of your serial numbers, e.g. eBound by Gunderson, your search will be much faster and easier for you to perform. In addition to the search, any notes that you can place about the physical location of your item will also speed up the process.

At this point we will assume that you have a good handle on your existing inventory and that you have the necessary tools to track what you have and where you have it stored. In addition to this portion of your NFA inventory you will also want to make up a list of all of the NFA items that you have dispositioned in the last year. This list will help you quickly and efficiently let your inspector know what is no longer in your inventory that may show up on their printout. In many situations your inspector will ask for a serial number that you may have dispositioned during the last year but it is still showing up on the registry. I would further suggest to save time during this particular process, that you make copies of the Form 3s or 4s for at least the last 90 days to prove the disposition. The inspector will most likely keep a copy of that disposition in an effort to make certain that the registry is correct.

In addition to the forms that have already been dispositioned from your inventory, I would also suggest that you have copies of anything that you have in process for disposition from your inventory. This will help your inspector also know what will soon leave your inventory.

At this point you will have completed the inventory of your NFA items and everything should be accounted for. It will also be at this stage that you will have completed the majority of your inspection and you should be feeling pretty good about the inspection, especially if you have organized your inventory.

Once this portion of the inspection is complete the only thing you have remaining will be your closing conference. If you have done well in your inspection your inspector will finalize your inspection with a summary of all of the issues of your inspection. If you have any violations in your inspection the inspector will cover those violations in detail with you and provide you coaching on how to avoid any similar problems in the future. In addition to covering any issues during the closing conference the inspector will cover a host of issues including any new processes or help that is available in the conduct of your business. Under normal circumstance your closing conference is very detailed. I know you can’t wait for it to be over with, but take your time and listen as this conference contains a lot of good information. Once this is concluded you will sign the closing documents and your inspections will be complete.

If during your inspection you experience a host of problems or issues, you may be summoned to what ATF terms a warning conference. At this conference, held at your local ATF field office, you would be officially warned about issues and specific corrective action that may be required to get your practices in order to comply with all ATF regulations. Rest assured if you attend a warning conference, follow on inspections within the next year will surely be in order. Use your time wisely before the next inspection to put your house in order. You will certainly want to correct issues that were covered in your warning conference and to improve on your overall operations.

Given the fact that your inspection feels like it is finally over, make no mistake, it is not. As certain as the formal part of your inspection is over; the clock is ticking before your local inspectors will return and initiate the process once again. Use this time wisely to learn from your previous experience and prepare for your next inspection.

If all else fails, call the NFATCA and we will gladly provide you with resources that can help your next experience be a little less painful. Come join us and dig into helping the entire community make a difference with the NFA industry. Log into www.nfatca.org and help preserve NFA ownership for you and your family today.