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I’m no fan of government regulation, but sometimes it serves a purpose and sometimes it’s an inadvertent subsidy to the manufacturers of over the counter migraine medication. This morning I got yet another ATF error letter in for a transfer to a colleague of mine in another state . . .

He’s a small FFL out west that sells his fair share of guns, but he transacts no NFA business, so he has no SOT. Seems reasonable. The gun control act of 1968 dictates that transactions that cross state lines must have merchandise go TO another licensee (for the purposes of this discussion, FFL and licensee are synonymous) to comply with federal law.

Without an SOT, the transaction is treated as TAX PAID via ATF Form 4 instead of TAX EXEMPT via ATF Form 3. The majority of the transactions I do to others in the industry are on TAX EXEMPT ATF Form 3. Most of the ATF Form 4 transactions to another FFL are an item that is already on existing ATF Form 4’s – like machine guns and silencers coming from a private owner in another state, or transactions like this where he’s decided he’s going to get a shiny new can and it makes no sense for him to pay for a $500 SOT to save $200 in tax liability.

So, this being the smart move, I prepared ATF Form 4s to his business and sent them out to the ATF with a $200 check on his behalf. This was in February of this year.

Processing time sidenote: Things are changing at NFA branch. This past week I got approved forms that were submitted anywhere from September of last year to February of this year. It’s a wide spread, but I see some improvements for taxpayers.

This morning, I got the error letter in. The error letter states that he has to have the local CLEO sign off. I called in and found out that this was from a relatively new examiner. I left a message stating that their understanding of the situation is incorrect and they should stamp the thing approved.

For years, the people of the NFA community have been clamoring for more staff, and this is what you get. More staff that’s not up to speed on technical nuances of interstate transactions. I think this is this what being a teacher is like, only I don’t use red pen.

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48 COMMENTS

  1. “For years, the people of the NFA community have been clamoring for more staff, and this is what you get. ”

    What, growing pains? So what? It’s not like it’s going to be like that forever. In the end, it will be well worth it, as they work through the backlog and start getting approvals done in a timely manner.

    • … True, assuming, of course, inexperience does not mutate into general apathy and government bloat. Why don’t we just take suppressors out of the NFA regulation statuses and treat them like any other firearm accessory or piece of personal protective equipment?

      I swear, if they could, they’d have us paying a $100 tax per pair of earplugs or eye protection too.

      • Why don’t we repeal the NFA?

        Why isn’t that even being considered by the NRA? Because it would reduce our perceived need for them.

        • How are “we” going to accomplish that worthy objective? Or the NRA. Yes the entire thing is unconstitutional but you have any idea of the politics of such? You want to cause massive demtard cardiac events?

        • Become a life member so you can help us vote in people that support that agenda.

          @neiowa If a small group of sexual deviants can get the government to protect and promote their perverted lifestyle choices, you’d think anything is possible.

        • @Mike_M
          Yes, those 8.4% of the population so immoral and perverted that they’re willing to defy God in their relationships shouldn’t be driving public policy. Government shouldn’t protect nor promote interracial marriage.

          We don’t support rules that say only some people* can have access to firearms, so why would we support rules that say only some people can have equal access to another basic civil right?
          In Loving v Virginia, Chief Justice Warren (appointed by Eisenhower) said:
          “Marriage is one of the ‘basic civil rights of man,’ fundamental to our very existence and survival”

          Every time a 2A supporter spouts bigoted nonsense about what other consenting adults do in their private lives, I cringe, because that plays right into the anti’s narrative about us and weakens our position.

          *Aside from criminals and the mentally ill, neither of which categories homosexuals fit into.

        • Interesting what makes you cringe… You’ve completely fallen for the propaganda used on both sides of the isle to influence people that cannot think critically.
          You want to compare race to “lifestyle choice”? Because it’s exactly that, a choice. Science has already proven beyond any reasonable doubt that homosexuality is not genetic. So that leaves mental affliction or choice. Even if it was genetic, alcoholism is genetic but people predisposed to it can still choose not to drink. It is insulting to any race that you would compare them to a bunch of perverts.
          Convenient how you oversimplify and draw parallels between marriage and guns. Every homosexual has the very same right to marry someone of the opposite sex. You think that right is so wide open they can marry anyone? Is the 2A so open that you can do anything you want with a gun? own any gun you want? Are we denying basic civil rights to pedophiles then? Are we denying basic civil rights to people that engage in beasiality? If you want to cite a historical fact then don’t forget that in the ’60s and ’70s homosexuals marched and demonstrated side by side with pedophiles. They only kicked them to the curb when it became bad press. Do you see the dangers of being so loose with your definitions of rights and discrimination?
          If they could have kept it “in their private lives” like they used to then I doubt anyone would mind. Instead they shove it in everyones face and parade down the streets with their bits hanging out doing their best offend everyone else.

          You cheapen your own argument when you quote a court decision. A court decision is only useful as ammunition in court. Judges don’t decide our rights and our values for us. Just look at how they have redefined the 2nd Amendment whenever it fits their purposes; or how long it took them to support equal rights. You cheapen every achievement won for equal rights by equating it with a bunch of immoral perverts that don’t have the strength of will to do anything more than what feels good.

          Do you really think it took 1000s of years to create a society that is “intelligent” enough to embrace immorality or is it more likely that it took all that time to produce yet another society that lost it’s way? This has all been done before and societies that have embraced moral values have flourished until they gave those values up. We haven’t evolved beyond making mistakes. We haven’t come so far that we are immune from destroying ourselves.

          I see your footnote that you’re OK with denying the basic human right of self defense to “criminals”. I think you must have meant ex-cons because a criminal isn’t a criminal until they’re convicted of a crime. Or would you deny someone their right to due process? Any ex-con can get a gun if they really want one and many often do. Any ex-con can get a gun to continue committing crimes yet it’s OK with you if an ex-con that has done his time and learned his lesson is denied his rights forever? They can have a second chance at freedom but they can’t preserve that freedom by defending themselves? Talk about some bigoted nonsense.

          I have some good news for you. If you can learn to think critically and not fall for the ridiculous simple-minded propaganda that comes from both sides of the political isles then you can support your beliefs without being a hypocrite. You can disagree with me, that is your right; but if you’re going to attempt to justify your opinion then you best bring an argument that can stand up to common sense.

        • I’d love to see the NFA repealed. Until then, I’ll be happy if they cut wait times down to a week or two. I got my last two e-filed Form 1s back in three weeks. That’s progress.

        • Think about the political obstacles to an outright repeal of the NFA. Can you imagine the wails of the Antis over de-regulating “destructive devices”? Do I take seriously the actual risk of widespread deregulation of DDs? Well, let’s see. When I was a child I sold dynamite, caps and fuse in my father’s hardware store. There was no paperwork other than writing up a bill of sale. If you paid cash and didn’t buy anything else we wouldn’t bother with the bill of sale either. You just had to be 21 and (probably) you would have to be a known customer. Today, black-powder is still sold over-the-counter with no paperwork. No matter what you or I think, Congress-critters would be terrified of voting for a repeal that would leave DDs unregulated.
          Similar problem with machine guns.
          How about “AOWs”? These would likely be treated as a Franken-weapon issue. We can’t even imagine what manner of “evil” devices someone might cook-up in his basement. The public imagination would run wild.
          If you want to spin-your-wheels to no avail, go ahead and try to eat the elephant in one gulp.
          If you would like to eat the elephant, follow the ancient wisdom: one bite at a time.
          The easiest chip would probably be to reduce the tax on silencers from $200 to $5 and allow the Class-3 FFLs to sell them based on an NICS check alone.
          Maybe next, go for a similar change to SBSs and SBRs.
          Possibly, chip away at DDs by removing the tax on the ammunition. At one time, ski resorts and highway departments used artillery to control accumulating snow to reduce avalanche risk. This use has – I believe – been constrained by limited availability of surplus artillery shells. Suppose an enterprising manufacturer designed a mortar that could serve the purpose. Some such manufacturer and a prospective ski resort operator could litigate to eliminate the tax on the shells; or, pursue a law change. Without such a “common sense” form of relief, peoples’ lives would be jeopardized for want of a competitive alternative to this prototype product being brought to market under a “reasonable” tax scheme. (A $200 tax on the tube with NFA registration ought to be sufficient. The $200 tax for each shell is unreasonable).
          Repealing the Hughes Amendment is probably unrealistic. My guess is that it might better be over-turned by a Federal court. We have principle on our side. We have the 2A on our side. We are supported by the Miller precedent. Remarks in Heller about MGs are mere “dicta”; they are not controlling. Nevertheless, the cost/benefit of pursuing the Hughes Amendment just isn’t there.
          The cost of overcoming political opposition would be higher than any other objective we might choose to pursue. Moreover, the political repercussions would undermine the political viability of other far-more-important objectives such as National Reciprocity where we likely have a good chance of getting Congress-critters from the 40 Shall-Issue States to pass such a bill. The benefit of repealing the Hughes Amendment is limited. I do not think we need more MGs for the purpose of “rearing up” a “well regulated militia”. We have a stock of old MGs, some of which are available at public ranges, and these can be used for training militiamen to the extent that they can afford to feed the MGs. We have a substantial population of veterans with military training in the effective use of MGs. In the low-probability/high-consequence event that the militia might be called-up to defend the nation against foreign invaders, the foregoing should be sufficient seed-stock to repel the first wave. The technology of full-auto and burst-fire is well understood. The Yankee ingenuity of machinists would ramp-up quickly to mass-produce MG actions for retrofitting to existing semi-automatic rifles.
          Let’s chip-away where we can and not waste time imagining leaping to nirvana in a single bound.

  2. I would be willing to train up to 500 new examiners, without pay. “Here. NFA application. Stamp ‘approved’, move to next application.” That should streamline operations rather quickly. You’re welcome.

    • That’s obviously how they train-’em on cashing the darn stamp user-fee checks. They got drones out there looking to cancel checks.

  3. I can fix this “with the stroke of a pen”.

    Eliminate the paperwork and bureaucracy currently required for any/all interstate transfers and all NFA items. Period.

    Save time, tax money, needless waiting, and improve the economy.

    • i agree. How can anyone read the above and not come to the logical conclusion that this process is a clear infringement on this basic right to keep and bear arms?

      • It should be obvious; but so many are so innured to the mind numbing level of regulation, certification, and licensing that is so prevalent today; they actually feel that getting a “blessing” from the local “public servant” aka the public master, is being an obedient serf; oh, I meant a good citizen.

        The Stockholm Syndrome is alive and well in the general population.

      • Clearly it is an infringement. But until it is someday repealed, we have to live with it. So should we not be happy if they make the process quicker?

        • Need to keep pushing for what you want, not what you would settle for. At every instance, whether there is a loss or a gain, never relent until our rights are restored and inviolate. This isn’t the difference of accepting blue when you wanted purple or having to go here instead of there.

          The real problem is we don’t take the momentum we have and use it to restore our civil rights. We defend and applaud the effort and rightfully so. For the most part, we are only preventing losses. We need leadership that will drive forward for gains until our rights are restored and inviolate. We need to remind government, the Constitution restricts government, not the citizens.

          Where’s the leadership on this? Who/what organization can we support that’s effective, has a plan and is brave enough to declare this and make it happen?

        • I disagree that we should eschew possibilities for marginal improvement and pursue only clear-cut gains. The way our system works is through incrementalism. While we were asleep at the wheel we lost our rights bit-by-bit. It is highly unlikely that we will regain them via great waves of complete roll-backs.
          Where is the leadership? For all NRA’s vaunted power in Congress I haven’t noticed their successes in pushing legislation through to restore our rights. I assume that they should be given some credit for stopping the last attempt at extending BCs and for restoration of the AWB. GOA likely deserves as much if not more credit for stopping new encroachments.
          Progress is largely creditable to SAF’s lawsuits and various State organizations pushing through liberalizing State legislation.
          I think we as voters need to decide where to focus our efforts. What issue would support the long-term viability of the 2A most? For example, I think that National Reciprocity would help the most. The Antis are mostly in the States with the most restrictive CCP issuance policies: MD, NJ, NYC, DE, CA. These are “breeding grounds” for hoplophobia. No one can carry a gun so no one sees that people can and do carry guns peaceably. In the 25 years I lived in NJ I saw exactly 2 non-uniformed people openly carrying guns. TWO! Imagine what that low level of gun-conciousness penetration does to the psyche of a voter who may have no friend or relative who hunts or target shoots. Such locations produce generations of voters with very warped ideas about guns.
          Imagine inoculating such jurisdictions with the handful of gun users who WOULD carry. Gradually, over decades, the voters in these States would accumulate a latent consciousness of a few acquaintances that do carry guns concealed. And? And NOTHING. No one gets shot by a licensed concealed carrier.
          The majority of us in free states take our gun rights for granted. We can carry in our home State; and often in neighboring States will reciprocity or Non-Resident permits. Those of us in such a situation are naturally myopic; we see that we have what we want where we spend our time.
          A minority of us in free States live near the boarder of a slave state where we can’t carry. Therefore, these few are conscious of the larger picture. Our national rights depend on Congress being compelled to respect the 2A; and, Congress won’t do so unless-and-until guns in population centers develop a normal relationship with guns.
          We PotG have our work cut-out for us. Those of us who live in free States must promote gun rights BOTH:
          – in population centers in our home-State which have a diluted relationship with guns; and,
          – in the slave States where there is NO carry and little recreational gun usage.
          I see the popularization of Carry – first CC, and following OC – to be the vehicle to normalizing the voters’ relationship to guns. One-by-one, single adults, married couples, and parents will begin to think about their vulnerability to criminal attacks. Some of them will be prompted to consider carrying a gun; or, at least, having a gun at home. If one-in-a-hundred such adults takes the initiative, 6 or 12 or 18 of their acquaintances will – eventually – learn that they are gun-owners. That knowledge will shock the non-committed voter to thinking about guns afresh. ‘Mary has been my friend for years. Seems like a level-headed gal. She’s got a gun! And she still seems pretty level-headed. What do I make of this?’ One or two or three of these acquaintances will consider becoming a gun owner.
          None of this is going to happen without carry. People who carry have to commingle with the majority who don’t carry. It’s not good enough for carriers to gather in coffee shops in rural areas. We have to “penetrate” the “market” in urban centers. That’s possible in free States with Shall-Issue laws. We have to MAKE it POSSIBLE in slave States with Won’t-Issue laws.
          It’s up to us – residents of free States – to recognize National Reciprocity as a priority. We have to communicate our priority to our respective Senators and Representative. We have to persuade them that they must get this done; if they don’t we will find someone to run against them in the next primary.

    • It is wrongful (not necessarily for our fine ATF application processors – they are doing their job, and [I am thankful that] they are swamped so business is good), BUT IT IS WRONGFUL (not just “wrong”) to say that their activities are protecting anyone. The ATF are just cops, there in minutes when seconds count, for the clean-up and the paperwork, and to tell you that you did it wrong and that you’re not a cop.

      Government/Legislation/Laws only govern the willing.

      • The ATF are not ‘cops.’ Trust me, if there’s a burglar breaking in your home and you call 911 you won’t be getting an ATF Special Response Team.

  4. I sent in Form 1 applications in late April. NFA Branch returned them in early Sept complaining that they were not in duplicate and one didn’t have an original ink signature. I fixed those errors and sent them back. Got my stamps within 2 weeks thereafter. Four and a half months including fixing my mistakes. The couple of people I spoke with at NFA Branch were polite and helpful. Not terrible. Not bad. We should give credit where credit is due. With enough staff and the right attitude, NFA Branch could give 4 – 8 week turn-around which would be OK.
    ATF is not at fault for adopting the NFA law; that beef is with Congress.

    • I agree…I have waited like everyone else for some long periods of time, but generally speaking, every time I’ve spoken with ATF/NFA they have been curtious and helpful and at times apologetic for the long waits and errors that can and do occur from both sides.

      • The perfect is the enemy of the good-enough. Would it be so terrible for NFA users to wait 4 – 8 weeks for their 1’st stamp? How many of us have just 1 stamp? If we could get our 2’nd . . . N’th stamp in just a few days that would remove most of our frustration; not all, just most of it.
        We complain about the $200 tax; and, rightly so. Yet, that amount had a value 10 times greater in the 1930s. Inflation has eroded the burden of this tax to a great extent. The registration issue is one – primarily – of principle. Our ability to perform our militia duty – should the time come – will be little impeded by registration of our NFA weapons.
        We PotG would be a lot better off if we could identify the solutions that might exist to our problems and then concentrate our efforts into pushing these good ideas through our Federal and State governments.

  5. If the approval process only took a few weeks, an error or two would be acceptable.
    If it takes them 7-9 months to process one piece of paper through their system, they better get it done ASAP and right the first time.

  6. Dumb question time.
    Can you go through the process of spending the $200 tax and get a stamp to hold till you find the can you want to buy?

    If it’s going to take months to get the stamp I would like to be protected from any changes in the market as a better can might be released for my needs after I have started the paperwork to get one.

  7. So you wanted them to hire more people
    They hired more people.. they’re new (duh)

    And you’re upset it’s not perfect?

    I bet you’re one of those people that honks at Driver’s Ed cars or gets flustered in the ‘cashier in training’ checkout line.

    • big blue – Click FC’s name above and it will list all his posts.

      Read them. That will clarify all for you.

      (Clue – FC was being un-charactaristicly, no, make that shockingly nice in today’s post.)

      I miss his caustic sarcasm. I remain hopeful it will soon return.

  8. It’s all a part of the tactic “If you can’t prohibit it, make it as complex as possible, and establish punishment for not following the mountain of rules and regulations”.
    The technique is described by Jack, the tyrannical leader of the choir boys in “Lord of the Flies”:

    “We’ll have rules!” he cried excitedly. “LOTS OF RULES! Then when anyone breaks ‘em-”
    “Whee-oh!”
    “Wacco!”
    “Bong!”
    “Doink!” (EMPHASIS added)

  9. A solution to NFA Branch’s back-log problem occurs to me. This week I’ve become the (proud?) owner of my first NFA stamps. Suppose NFA-B were to give me a computer-user’s account now that I am an identifiable BC’ed NFA tax-payer. Then, tomorrow, I could fill-out a new NFA form, enter my bank/card info and print a hard-copy of my application form in a “tentatively-approved” status. A few days later, I’d receive a new NFA stamp in the mail with a serial number matching the serial number on my hard-copy form. I lick the stamp and affix it to my form. Now, I’m good-to-go. NFA-B could manually review my application and complete the approval and filing process at their leisure.
    Granted, in filling out my form there might be some mistake. NFA-B’s computer could catch some sorts of errors such as my trying to submit a Form 1 on a machine gun. (Maybe I’m being overly optimistic here; if so, please forgive me.) It’s probably not practical to automate approval of AOWs, maybe not for DDs. Even so, I don’t see much room for more than some minor correctable clerical error for a SBR/SBS/Silencer.
    There remains the possibility that between my last investigation and my current application I might have become a prohibited person. In almost all cases, such a possibility could be mitigated with a NICS check, presumably performed on-line within a few minutes. When NFA eventually reviews my application they could do whatever further BC they might do. The risk of something new coming up is exceedingly remote and the consequences are unlikely to be problematic; certainly no worse than if I should become a prohibited person while holding the stamps I’ve just waited 4 months to receive.
    Under my proposal, NFA-B could give first priority to tax-payers applying for their 1’st stamp. These applications could probably be all cleared in a month or so. Established NFA tax-payers’ applications could be manually processed on as delayed a basis as the NFA-B might process them. We don’t care whether they do it in 3 months or 3 years; we will have our tentative approvals in a few minutes and our stamps in a few days.
    That would reduce our NFA-B complaints to the objections – on principle – to the ideas of an excise tax on a 2A right and the establishment of a federal registry on guns of NFA type.
    Can anyone see a practical objection to my proposal? If there aren’t any that can’t be worked-out, why don’t we NFA tax-payers petition for a redress-of-greviance by way of some such expedited procedure?

      • Government is a blunt tool wielded by clumsy craftsmen. That’s simply the way it is and we might as well recognize it if we expect to change it in any way.
        It can change for the better; it has at least once that I know of. I worked briefly (9 months) for a Federal agency when I was 22. We had two – largely redundant – reporting systems. Everyone relied upon the secondary system and ignored the primary system. That didn’t work for me; so, I ignored the secondary system and relied on the primary system. It took about 5 years for the agency to get its head around the fact that I was right. But, then, they abandoned their secondary system and relied exclusively on the primary system. Probably saved industry tens of millions of dollars in the decades to follow.
        We PotG need to figure out how to work smarter with our politicians and government. Chip away at everything we can identify that we might have a good chance of changing.
        Look at what SAF has accomplished along with supporting and competing organizations in litigation. Each lawsuit one one or another narrow issue is accumulating to reconstruct our rights. Sitting back and waiting for universal respect for “shall not be infringed” won’t get us anywhere. Small steps will accumulate eventually to a much better environment.

    • I think the ATF would already have a more efficient system if the NICS system actually caught criminals. Most people stopped by NICS are false positives, and it often takes police agencies a long time to update their criminal records with NICS. It doesn’t work, it never has, and it is living proof that background checks never will work. We have poured an ungodly amount of tax money into making it work…
      Also there is the possibility that their source of funding won’t allow them to become more efficient.

  10. See if the parallels fit:

    1st Amendment: Federal 10 % excise tax on all books, paper, newsprint, ink and pencils — + $200 transfer tax on any high volume printer.

    4th amendment: Federal 10 % excise tax on the value of any dwelling or personal property you decline to have searched. +$200 transfer tax on any seizure to defray the costs of search and seizure.

    5th amendment : 10% excise tax on the value of any property or liberty you want protected by due process + $200 tax on EACH demand to remain silent

    6th Amendment: 10% excise tax on all fees for representation by counsel +$200 tax on each witness against you that you demand to confront

    7th amendment: 10 % excise on the value of all civil claims for which jury trial is demanded +$200 tax on each finding of fact you wish not to have the judge overturn.

    Puts things in perspective, doesn’t it?

    • Absolutely clear! Now, get these analogies into a context where we can convey them to some effect.
      Find some proposal:
      – a bureaucratic change to recommend to ATF
      – a proposed rule-making to change an ATF rule of procedure
      – a proposed change to the law, e.g., to the NFA
      that would serve to create a forum in which these analogies could be articulated to advance the proposal. Or, perhaps, no good proposal for a law/rule/procedure change comes to mind. Then think of a lawsuit that might be advanced.
      It has occurred to me that good arguments could be articulated for why the SBR or SBS is well-suited to home defense. Under Heller we have a fundamental right to handgun arms for self-defense in the home. It would be a small incremental step to argue that some people (e.g., Granny) has a fundamental right to a SBS for self-defense of hearth and home and she should not be obliged to wait 6 months and pay a $200 tax to take a hack-saw to her late husband’s double-barreled shotgun. Where is the interstate commerce of her sawing-off the barrel of a gun she will keep in her home?
      Likewise, challenge the inequity of a $200 tax on a silencer compared to the Medical Devices Excise tax. By now, there should be a large enough body of history of registered silencers to make a case that they are rarely used in crimes. The tax does not serve a material useful service in reducing crime; instead, the tax inhibits the lawful uses of protecting hearing and noise abatement at ranges near populated areas.

    • I paid nothing when I registered to vote, nor any time I went to the polls.

      The administrative expense of that exercise of the right to vote was absorbed from general revenue, i.e. the taxpayers. It was no doubt a minor expense since I was not fingerprinted, NICS checked, nor did I supply 3 character references for the local authorities to consult with in order to register, nor was any further verification done every time I voted, to make sure I was still qualified.
      Poll taxes, to defray the cost of elections, are unconstitutional. Unpaid taxes of any kind do not justify denial of the right to vote.

      The principle is “The power to tax is the power to destroy”.

      Why then, can the Government impose any tax, or charge the citizen any “fee”, for the exercise of any right? In particular, for the exercise of 2nd Amendment rights. At the very least, any bureaucratic burden of expense for the “regulation” of any right should be absorbed by the people as a whole, for as long as they are willing to put up with that expense.

  11. It looks like you are incorrect. This is from the back of the form 4. The only way cleo sign off is not required is if your friend was also an sot.

    Law Enforcement Certification. Item 17 must be completed for an individual transferee, unless the transferee is licensed as a manufacturer, importer, or dealer under the GCA and is a special (occupational) taxpayer under the NFA at the time of the submission of the application for transfer. The chief law enforcement officer is considered to be the Chief of Police for the transferee’s city or town of residence; the Sheriff for the transferee’s county of residence; the Head of the State Police for the transferee’s State of residence; a State or local district attorney or prosecutor having jurisdiction inthe transferee’s area of residence; or another person whose certification is acceptable to the Director, Bureau of Alcohol, Tobacco, Firearms and Explosives. If someone has specific delegated authority to sign on behalf of the Chief of Police, Sheriff, etc., this fact must be noted by printing the Chief’s, Sheriff’s, or other authorized official’s name and title, followed by the word “by” and the full signature and title of the delegated person. The certificate must be dated no more than one year prior to the date of receipt of the application.

    • I’d be willing to bet dollars to donuts that FirearmConcierge is correct.

      As FirearmConcierge mentions above, he prepared the “ATF Form 4s to his business”. This is not an individual thus CLEO sign off, fingerprints and the Certification of Compliance are not needed.

      Or at least that’s my take on it…

  12. Which I why don’t support bureaucracy in general. The government is perfectly happy to delay, deny, and over charge you for stuff. They don’t mind breaking their own rules to do so. Perhaps they’ll abide by their own rules and accept your forms, but that’s a one-way street. If John Q. Taxpayer breaks the rules, they get the Taliban treatment.

    Less government, lower taxes, more freedom.

  13. Relax. It’s actual PROOF that they have added new examiners. Which is great for the long run and the big picture. Your error letter should clear in just a few weeks, if that.

    • Relax, government is only serving to propagate themselves. The fact that you still think a minor improvement to an unconstitutional system by an agency that only reports to the President, is good is part of the problem. Part of the travesty is you think this improvement is good enough and will live with it instead of resolving the root problem.

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