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ATF is trying to slap new, onerous restrictions on pistol stabilizing braces, which will affect every person who owns one or owns a gun that’s equipped with one. The public — that’s us — can comment on these proposed restrictions and ATF must read and respond to every. single. comment. Believe it or not, this can and does have a very real effect.

Please visit the Federal Register HERE — like right now! — and submit an original comment (DO NOT copy and past comments from anyone else). Explain why the proposed pistol brace restrictions are not acceptable and making it clear that you oppose them. Also, keep it clean. The ATF can and will toss out all comments with foul or abusive language.

Continue reading for background information on the proposed pistol brace restrictions, some suggested talking points for your comment, and a recent(ish) example of public outcry via comments on the Federal Register causing ATF to completely abandon a gun control scheme:

The FPC video above explains the proposed new guidance pretty well. It’s basically the December proposed guidance — which I tore to shreds line-by-line HERE — with the addition of an asinine points system.

It’s bad. It would force stupid, arbitrary, nonsensical, and horribly vague restrictions on how the owner of an arm brace-equipped pistol is allowed to configure his or her gun.

So let’s fight it. Right now, this very minute, you need to go leave a comment on the Federal Register that clearly states you are against the proposed rule. It’ll take you 60 seconds.

Here are a couple comment rules to keep in mind:

• No profanity
• Anonymous comments will not be considered, so fill out the name and info fields
• Don’t copy-and-paste another comment; yours must be unique (ATF combines identical comments and treats all of them as a single comment)

Here are some topics you may want to include in your comment:

• Millions of pistol brace-equipped firearms are owned by law-abiding people who purchased firearms or pistol braces in good faith with the ATF’s express acknowledgement of their legal status. These new rules may turn many of these people into felons overnight.
• ATF’s proposed “objective” guidance is vague and highly subjective, with no quantifiable metrics. It increases confusion and fear among legal gun owners and manufacturers rather than provides clear guidance to follow.
• Many of ATF’s “objective factors” are non-sensical and self-contradictory with previous ATF rulings. For instance, ATF has always affirmed that resting one’s cheek on a pistol’s receiver extension (buffer tube), stabilizing brace, or pistol cheek rest (example) is entirely legal and acceptable. How, then, can the use of optics designed for this cheek placement create an illegal configuration?
• Many of ATF’s “objective factors” would directly discriminate against individuals based on physical stature and physical abilities, such as the very subjective “so heavy that it is impractical” weight limit. This factor is entirely vague and undefined, and would clearly violate equal protection of the laws under the 14th Amendment, the Civil Rights Act, and the Americans with Disabilities Act.
• This is a direct attack on disabled Americans who have difficulty controlling a large format pistol due to injury or other disability, such as the disabled combat veterans for whom the pistol stabilizing brace was originally invented.
• ATF states that the purpose of the National Firearms Act is “to regulate certain weapons likely to be used for criminal purposes.” With approximately six million pistol brace-equipped firearms in private hands in the United States and literally one known criminal act committed with such a firearm, it’s clear that in no way do these guns belong in the purview of the NFA.
• In point of fact, the United States is the only country in the world to specifically restrict rifles based on barrel length, further proving that the entire concept of “short barreled rifles” requiring unique regulation is not based in fact or reality. These firearms are not “likely to be used for criminal purposes” and do not belong in the purview of the NFA.
• Clear infringement of the Second Amendment
• ATF’s unclear, secret, capricious, and ever-changing rulings related to pistol braces created this situation. Not only do these new, vague guidelines not help in any way, it is unreasonable to retroactively apply them to persons who followed previously-published and even unpublished guidelines in good faith in the past.
• Forcing law-abiding gun owners who might be in violation of these subjective, unclear new rules to register with the National Firearms Act or destroy their legally-purchased property is unreasonable.
• What else do you have? Comment below this article with other topics and avenues of attack on ATF’s latest rogue, ridiculous action.

More info can be found at FRAC and FPC.

And, yes, leaving a comment does truly make a difference. Here’s an example:

In 2015, during the Obama administration, the ATF gave up on banning M855 ammunition after receiving an overwhelming barrage of public comments against the proposed rule. From The Washington Post:

The Bureau of Alcohol, Tobacco, Firearms and Explosives said Tuesday it was backing down from a proposed ban on manufacturing and selling one of the most popular bullets used in AR-15 semiautomatic rifles.

The agency pulled the plug early, with still a week to go before the end of a one-month informal comment period on the proposed rule change that would have targeted these armor-piercing bullets. The ATF noted it had received more than 80,000 comments, and “the vast majority of the comments received to date are critical of the framework, and included issues that deserve further study.”

TTAG covered the news HERE.

Heck, the ATF quickly backed off on similar brace restrictions last December, literally ending the comment period early and withdrawing the proposed guidance entirely, due to the tens of thousands of public comments.

Let’s do it again. Go comment.


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  1. Alright pretty please ATF don’t take my inherent rights!

    Thank ya massa!

    Anything I’d post on their website wouldn’t be appropriate enough for them to consider they can F off….

  2. I responded by saying “I write in opposition to the proposal. I remind you that the original brace was designed to assist disabled veterans who sacrificed mobility and limb in service to our nation. Your proposal will make instant felons out of millions of my brothers in arms.” I signed it with my name and retired rank. We shall see. I suspect that this and the FRT bans will go into effect regardless of our opposition. It’s part of the communist agenda to destroy the 2nd and the entire Bill of Rights now that they have China Joe in the office.

    • @ Michael A Crognal….thank you for your excellent post, I have two friends of mine that are disabled veterans and are avid shooting sportsman that use assisting apparatuses and braces for both range work and hunting!

  3. With the “Biden” regime installed the wants will have no effect on implementation by the useless and unconstitutional AFT. However, it could influence nthe lawsuits afterwards and other future events.

  4. After Jim Crow Gun Control joe asked an Afghanistan leader in a recorded phone conversation to cook the books about Afghanistan military strength and soon after Jim Crow Gun Control joe left people in Afghanistan behind for the wolves and armed terrorists in Afghanistan with mountains of US Taxpayer paid for US Munitions I will never again lower myself to commit on some nitpicking ignorant ATF Gun Control Nazi Racist Rot.

    Hopefully this ATF Gun Control centers around the top brass and not among the rank and file. It’s like a Big Newspaper supporting some marxist manure when the reality is it’s a few at the top posing as many.

    The ongoing knee jerk mentality behind there being little difference between citizens who own and use firearms responsibly and the criminals who misuse anything they can get their hands on including their own hands and feet must end and a wide, impassable margin established between the two.

    No matter where Gun Control has been for the past 3 centuries or where Gun Control goes only misery, death and destruction follows. The only way to Kill Gun Control is kill it with its own disgusting History. First problem is around 75% of Gun Owners cannot define Gun Control by its history so how in the hell can they define Gun Control for others? They can’t and until that happens there is no viable defensive front line for The Second Amendment.

  5. They have the page set up to make commenting by pasting from a word processor extremely difficult. Your tax dollars at work — NOT!

  6. I’ll post my comment, in case anyone is interested:

    “ Pistol stabilizing braces, used as intended, are a genuine improvement in shootability and access to defensive and sporting firearms for those who are differently able. In particular, newer designs, such as the “tail hook” (the easiest to use and most shootable for people missing all or part of an arm) and the magpul “bladed” style (which is surprisingly effective when adjusted properly for the user and braced against the forearm or elbow—and the easiest design with which to manipulate the firearm safely with good muzzle control) are a huge advance over the earlier “strap it onto your arm” style of brace. It would be a travesty if misguided attempts to compare braces visually to stocks or try to equate certain brace materials, widths, or functional concepts to stocks were to stifle the currently active and innovative market which is improving shooting for the differently abled. It is foolish to conclude that the earliest “strap on” braces are the end of permitted innovation in one hand shooting implements. The strap on braces are often prohibitively difficult to employ one-handed—and they are demonstrably more difficult to use safely (strapping a firearm to your arm so that you cannot remove it without assistance makes muzzle control very difficult). Newer designs which the proposed rule would tend to eliminate are improvements in every way. The next designs should be even better. Don’t discriminate against Americans who need to use their firearms one handed. …not for the sake of trying to avoid something that “looks like a stock.”

  7. Comments submitted:

    It is my belief that Federal Regulations should only be data driven to avoid capricious regulation brought about by, say. political pressure and that if the data do not support the regulation it shouldn’t be considered. This represents a scientific approach. I see no data to support the claim that handguns with pistol braces are “gangster type weapons”. Since ATF has allowed a number of different pistol braces to proliferate over a period of several years, relatively unregulated with the exception of regulating the distance between the butt end of the brace and the handgun’s trigger, it is reasonable that if attaching a legal pistol brace to a handgun makes it into a ““gangster” type weapon” there should be proof in that a significant increase of crimes have been committed with these “gangster type weapons”, yet no reasonable statistics are presented to prove that this is the case. “Indeed, firearms with “stabilizing braces” have been used in at least two mass shootings, with the shooters in both instances reportedly shouldering the “brace” as a stock, demonstrating the efficacy as “short-barreled” rifles of firearms equipped with such “braces.” [9]”. No further details were set forth. Did the stabilizing braces really facilitate the crimes, or was a pistol with a stabilizing brace just what the perpetrators had available? Could the crimes just as easily been committed with any number of other legal firearms? Over the ten or more years that stabilizing braces have been available two instances is hardly a crime wave given the numbers of murders that have been committed with conventional handguns, sharp objects, blunt objects, and even human hands over the same period. The lack of crimes committed with shouldered stabilizing braces could as easily be used to justify the elimination of short barreled rifles from those weapons included in the National Firearms Act. Without better supporting evidence the regulation should not be promulgated as it is capricious, politically motivated, and not science based.

    The distance between the butt of a rifle and the trigger, that has been the only dimension of pistol braces regulated significantly by ATF in the past, rightfully has definite influence on the accuracy of rifles. This is demonstrated by the fact this dimension is adjustable for most competition and long range rifles. I have had the opportunity to try shouldering several braced pistols in the past and find them short enough to limit accuracy to the extent that accuracy approaches that of the brace used in the intended manner attached to my forearm. Once again Federal Regulation should be data driven and approached in a scientific manner, so has the ATF conducted studies with groups of both men and women representing a reasonable range of human dimensions to see if shouldering a pistol brace does significantly enhance accuracy over using the brace in the intended manner attached to the user’s forearm? This needs to be a carefully controlled study and if it doesn’t show a very significant difference the regulation should not be promulgated.

    Why after approving many different versions of pistol braces and allowing hundreds of thousands to be sold without so much as separate serial numbers to keep track of their proliferation does ATF propose to add these plus the pistols they are installed on to the list of most highly regulated arms in the United States? Is this driven by hard statistical data on criminal activity or is it being done capriciously to punish law abiding Americans, particularly including disabled veterans, who enjoy the shooting sports and to satisfy political contributors to the current Administration? If there is no scientific data supporting stabilizing braces leading to increased criminal activity the regulation should be dropped from consideration.

    How can an arbitrary scoring system as to whether a pistol equipped with a stabilizing brace not be a recipe to allow agents to dole out arbitrary punishment? Words like “could”, “may”, or “likely” have no place in regulations of this sort.

    Are we to somehow interpret the emphasis on one handed operation as evidence that ATF will soon move to ban the two handed pistol grip? Some of these heavier pistols can be quite accurate when gripped with two hands, one on a pistol grip and one on a forearm that attaches to the barrel without an additional handle.

    “ATF recognizes that these factors may affect industry members and members of the public, as they may manufacture or already own firearms with a “stabilizing brace” attached. ATF wants to assist affected persons and industry members and provides the additional information in this proposed rule to aid them in complying with Federal laws and regulations.” The only way for ATF to genuinely do this retroactively, with no grandfathering provision, involves direct, full compensation of the affected parties.

  8. That picture of the dumb dog at the computer is very appropriate as only a dumb dog would think the ATF pays the slightest attention to the letters it receives. Biden ordered this and the ATF obeys just as they have obeyed other presidents or gone ahead completely on their own when they wanted to ban weapons like the shotguns the street sweeper, the Spas-12 , and even leather wallet holsters that are not even a firearm, now that was really far out.

    Its a done deal and those that do not agree live in the twilight zone.

    • Do you understand how this works? The ATF HAS to reply to comments made. There are currently almost 200k comments made. It could take them years to get through all of them. ATF proposals have been canned in this way. I agree that this whole thing is all political theatre to them, but when they see they have to do actual work, that can be a huge turn off. I totally disagree: I think when they see how much they’re going to have to go through, this regulation will be DOA. Now that isn’t how it SHOULD be done. They have no constitutional power to enact anything, but sometimes you have to play them at their own game.

      • quote—————-They have no constitutional power to enact anything, but sometimes you have to play them at their own game.——————-quote

        Agreed they do not have the Constitutional power but the reality has proven hundreds of times the Constitution is only good for wiping your ass with it. The ATF is a law unto itself.

        Yes its illegal I agree with you but that never stopped the ATF from acting and getting away with being jack booted thugs. They almost always win UNLESS people from Congress threaten them as when they tried to ban .223 green tip ammo. There were too many cheap ass Republican Congressmen that liked its low price. It was one of the rare occasions when Congressmen grew balls and stepped in.

        But lets face reality no Congressman in their right mind is going to sanctioned short barreled rifles, the rifles of choice for drug gangs and Mass Murderers. That would be pure political suicide.

        Lets face cold hard facts even the majority of gun owners know the short barreled rifle is of no use what so ever to law abiding people. It cannot be carried comfortably like a pistol nor is it very concealable either. It has no sporting use at all and for home defense Biden really was correct as there is nothing more deadly on earth than a shotgun at point blank range. And shotguns usually do not over penetrate and sail projectiles through several walls and out through the neighborhood killing innocent people either. Short barreled rifles give decent law abiding gun owners a bad name and are add more fuel to the fire to ban semi-auto rifles altogether. Anyone who cannot see that needs to be put in a straight jacket and the key thrown away.

        The sane gun owners who are in the majority know Biden is actually doing them a favor by banning short barreled rifles but the ban is not really a ban at all, just register it and get vetted as that is keeping the weapons out of the hands of gangs and nut cases. Its a win , win for everyone , that is if your sane enough to understand it.

        • So if I disagree with this 2nd rule reversal I’m insane? Gun owners thinking Biden is doing them a favor? What planet do you live on? You sir, are clearly a Fudd.

  9. KABUKI THEATER (courtesy of the powers that be)

    Braces will be:
    Turned in
    or Hidden (to be used with careful discretion)

    This was a done deal from the beginning.

  10. FWIW (duplicate of comment posted on previous article):

    The ATF’s proposed rule redefining pistol braces is an attempt to hold literally millions of law-abiding gun owners responsible for the ATF’s past decision to allow such braces and braced pistols to be sold. The ATF’s notice estimates that 3 million such braces have been sold over a period of nearly 9 years, while the Congressional Research Service cites estimates of 10-40 million.[1] All these braces or braced pistols were bought under the belief that they were legal, based on the ATF’s earlier determination. For the ATF at this late date to request a do-over is an unfair imposition on brace owners, and would inevitably result in some owners becoming unwitting felons if they fail to receive notice that the legal status of their braced firearms has changed and thus do not register them. It would also overwhelm the ATF in processing millions of registrations, and create legal uncertainty for gun owners and law enforcement during the period while registration is pending.

    While the ATF’s proposed rubric provides greater detail than its 22DEC20 proposal, it still has many criteria that are subjective, are dependent on the individual owner (such as criteria based on how the braced firearm is held), and/or change the status of the firearm as the owner configures it for particular uses (for example, switching from a low-capacity magazine for hunting to a standard-capacity magazine for home defense). Again, some number of owners will become unwitting felons for failing to register under the belief that their braced pistol does not require registration, but where the ATF’s evaluation differs.

    It also appears that the criteria are intended to define the majority of braced pistols as SBRs, including numerous models that have been sold for years under the apparent approval of the ATF. If the ATF’s view is that the vast majority of braced pistols are, in fact, SBRs, then it is clear that SBRs should not be subject to the registration requirements of the National Firearms Act, as they are not dangerous and unusual weapons, nor particularly suitable for criminal use. The ATF has essentially conducted an unintended experiment to see how gun owners would respond to having access to SBRs without registration, and overwhelmingly gun owners have shown that they find such firearms to be useful enough to be worth purchasing millions of them, placing them into common use, but without any corresponding increase in criminal use.

    The Notice cites two mass shootings conducted with braced pistols. However, even in these 2 attacks (out of several million braced pistols), it is unclear whether the weapons were selected because they could serve as SBRs, or they were merely what appealed to the murderers from available options at the time of purchase. There is no evidence that these attacks would not have been equally deadly if perpetrated using either an unbraced pistol or a conventional carbine. Or, for that matter, if perpetrated using a pistol illegally equipped with an actual rifle stock.

    The clear result of the ATF’s experiment is that the NFA is outdated and in need of reform.[2] Such reform, of course, is the responsibility of the legislature, not the ATF. However, until such reform is enacted, the ATF should focus on the purpose of the law, which is to register dangerous and unusual firearms to reduce their availability to criminals. Since the widespread ownership of several million braced pistols by responsible owners for lawful purposes shows that these firearms are not particularly dangerous or unusual, the ATF should choose at this time to maintain the legal status of braced pistols.

    It is possible that the ATF’s motivation in trying to assert, several years late, that braced pistols fall under the NFA is to instill respect for the law by prohibiting what has become a recognized work-around to NFA registration. However, any such desire should be balanced by the adverse impact of inconsistent definitions, where the ATF changes its approval or disapproval of particular configurations well after the public has relied upon them when purchasing firearms and/or accessories. Inconsistent, capricious changes to the legal status of firearms can only undermine respect for the ATF and the laws it is obliged to uphold, and would do far more damage to respect for the law than does allowing a legal work-around.

    [1] –
    [2] – Problems arising from the defintions of the NFA are not limited to the distinctions between braced pistols and SBRs. For example, the legal status of firearms with 2-piece receivers has been a recent issue of contention.

  11. The next step if and when ATF acts will be a law suit, probably by a disabled vet. The comments submitted is a big crowd sourced list of ideas for his or her lawyers.

  12. Submitted.

    Several of us wrote “this proposed change will make millions of gun owners instant felons.” If I were a gun grabber, I’d be wetting myself with joy at this thought. While true and odious, I would not advise leading with this. I pointed out the extraordinary 5th Amendment problem with this rule and flat out said I’d be among the many to flood the ALJs with suits. Also that the rule is clown car stupid (actual legal term) on its face.

  13. Itd be my guess that the BATFE might let disabled people use the pistol brace.
    It’s not worth losing an arm over though.

  14. This is fruitless but evidently there a bunch of people that think that the ATF or the government actually cares about your comments, feelings or the second amendment.

    As someone who has filed quite a few “witness slips” in my state against bad laws without ONE success let me let you in on how these things work.

    First the whole brace vs SBR thing was strengthened on the ATFs side when people who were obviously not disabled shouldered them in YouTube videos. The ATF has these videos and will use them to support their side of this. “Here is about 100 people using these as SBRs and that’s illegal.”

    The only reason the DOJ stepped in for a while was because an election was coming up and Trump could likely win. While he wasn’t exactly a pro 2A POTUS, he wasn’t anti 2A. Biden is very anti 2A and will make sure that braces are gone.

    Comparing this to the M855 ruling is a farce. M193 is a better round against living targets, M855 is better against barriers. M855 is not armor piercing and M193 will do more damage to an actual person if they are hit. It was basically a dog and pony show and so is this.

    The way I see this is everyone that submits a comment that the “ATF must read and respond to every. single. comment.” is going to get a form letter back.

    That letter is going to say: Thank you for your interest, yada, yada, yada but weighing all of the evidence we have decided that stabilizing braces will become illegal on 1/1/2022.
    Thank you for your comment

    It will probably be a bit more detailed, explaining the point system they use and the ADA but IMO the outcome has already been decided.

    Many will say I’m rolling over but in reality I’m just being a realist. They don’t care, this administration doesn’t want you to have any guns, they are just testing the waters. This is just the beginning.

  15. Nobody is reading anything, nobody cares.
    The NFA and GCA need eliminated and the ATF needs reduced to a small regulatory agency who’s main purpose is to ensure warning labels are correct.

  16. I wonder if this attempted ATF Brace Rule applies to my high velocity folding wrist and shoulder fired slingshot also…….

  17. 1. (01 is 52,967 : (02) 7,103 : (09) 128 : Total of 60,207 on (01/02/2021 A.D too! On 01/02/2021 to 06/30/2021 A.D . 1st Month Dates Done . The 2nd Month 07/01/2021 to 12/31/2021 A.D. Note: we lost 9877 Smaller Gun Stores Retailers business too! Now how many is Left on 2nd months Period ! Count is (01) F.F.L.s 40,226 : (02) : 2164.5 (09) 128 : total is 42,518.4 Retailers Dealers Store Fronts to: is left too!

  18. Now that the “Biden” system is in place, the wishes will be granted by the ineffectual and unlawful AFT. But it may affect further litigation and other things that happen in the future.

  19. Submitting your comment is a straightforward process that can have a significant impact on the outcome of these Drift Hunters regulations. Act now to defend your rights as a gun owner and ensure that your voice is heard in this important matter.

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