Seven comment letters, filed with ATF and published in full.
On August 1, 2026 we filed one letter for each of the seven proposed rules open this summer that touch how a private sale between two ordinary people is documented. Every letter is here in full and unedited, with its docket, its rule number and its tracking number.
Seven letters, one day.
Each supports a rule, and asks for one narrow fix.
We published these ourselves because ATF posts comments to its own public docket on a delay of roughly a week — which, for a filing made this close to a deadline, falls after the window has already shut. Anyone weighing whether to write in can read what we said, and why, while it still helps.
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01
The permit exception to the background check
We support the rule. It cleans up real ambiguity in when a state permit stands in for a background check. We ask ATF to carry one piece of its own reasoning into the final rule, and we point out that two rules open at the same time would each rewrite the same section heading differently — whichever is finished second silently overwrites the first.
Read the letter (PDF) -
02
How long firearm records must be kept
Two different changes, and we take a different position on each. Replacing open-ended retention with fixed periods for dealers: we support it. Attaching any federal retention period to the form used for a private sale: we oppose it, because none has ever applied and ATF's own explanation concedes as much. ATF says a shorter record encourages more voluntary checks — we ask it to follow that reasoning where it leads.
Read the letter (PDF) -
03
What it means to be "engaged in the business"
We support the rule. A federal court vacated the 2024 version last June, holding it departed from the words Congress actually wrote — and that the ruling applies to everyone, not only the parties who sued. Our letter is about fidelity to the enacted text, and about the line between documenting one specific sale and dealing in firearms.
Read the letter (PDF) -
04
Stabilizing braces
We support removing the 2023 factoring criteria, which returns classification to the statutory definitions and the design of the individual firearm. We ask the final rule to say plainly that the 2023 rule was struck down as unlawfully adopted — not quietly dropped as a change of mind — and to address the position of owners who complied with it while it stood.
Read the letter (PDF) -
05
The Form 4473 revision
The longest of the seven, and the one that matters most to us. This rule writes the first definition of a "private-party transfer" in federal regulation — language that will be quoted for decades. We support the part that separates running a check from being part of the sale, and we oppose stamping a private-sale category onto the federal form itself.
We also object to something specific: a footnote tells the public that dealers must follow this rule and a pending upcoming FBI rule, without naming it. We looked for that rule in every place the public can look and could not find it. You cannot meaningfully comment on half a proposal, so we ask ATF to identify the rule or delete the reference.
Read the letter (PDF) -
06
Electronic recordkeeping
We support letting dealers keep their records electronically. Our concern is the people whose personal details sit inside those records. The rule tells a dealer to store them "securely" and then never says what that means. We ask ATF to name an existing, maintained security standard rather than leave the level of protection to each vendor's judgment.
Read the letter (PDF) -
07
Sales that don't happen face to face
We support the rule, and we ask for four refinements. It would require every buyer in one of these transactions to prove their identity to a private company — handing over identity documents and a live capture of their face, with liveness detection. That is not optional under the rule as written. The rule says nothing about what that company may keep, for how long, or what else it may do with it. It also points to a technical standard without saying which edition, which matters more than it sounds.
Read the letter (PDF)
Public comments, not legal advice.
These are public comments on proposed federal rules, filed by a small veteran-owned company that builds tools for documenting lawful private sales. They are not legal advice, and they are not a prediction of what ATF will do.
Every quotation in them was checked against the government's own published text before filing. Where we thought a proposed rule was right, we said so — we did not oppose all seven on principle.
