41P Final Ruling Pushed Back to (at least) December 2015

41Pdec15A final decision on ruling 41P – the rule change that would add further impediments to owning NFA items such as silencers and short barreled firearms – has officially been pushed back.  Again.  Previously expected nearly a year ago, a decision was pushed back to the end of 2014 and then again to “sometime in May 2015.”  More recently, the NSSF released a statement that a decision would likely not come for another six months at a minimum.

Yesterday, the NSSF’s prediction was officially confirmed as the OMB’s Office of Information and Regulatory Affairs website was updated to reflect a new final decision date of “12/00/2015,” meaning “sometime in December 2015.”

Keep in mind that this does not mean that 41P will go into effect in December or, for that matter, that a decision will actually be reached by that point.  Several dates have been given as the final action date, yet those dates have come and gone with only more delays.  In addition to addressing each concern raised in the 9,500+ comments received on the matter, the NSSF brought up a number of technological and implementation hurdles that would need to be addressed – perhaps no small obstacle given the history of eForm 4 implementation, management, maintenance, and (pending) re-launch.

Despite all of that, a decision will be reached at some point, whether it is in December or later.  However, that decision could very well be to say that “this is all rubbish, let’s scrap the idea.”  Regardless of when the decision comes and what it is, we maintain that there is no time like the present to jump into the NFA game and doing so with an NFA gun trust is an easy way to do it.

The abstract of the rule change reads:

The Department of Justice is planning to finalize a proposed rule to amend the regulations of the Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) regarding the making or transferring of a firearm under the National Firearms Act. As proposed, the rule would; (1) add a definition for the term “responsible person”; (2) require each responsible person of a corporation, trust or legal entity to complete a specified form, and to submit photographs and fingerprints; and (3) modify the requirements regarding the certificate of the chief law enforcement officer (CLEO).

Join the 41P discussion on the GunLink forums or add your comments below.

5 Responses to 41P Final Ruling Pushed Back to (at least) December 2015

  • GunLinkBlog says:

    The timing puts a possible decision very close to an election year. Do you think that will effect anything?

  • Mike Hawk says:

    What problem is 41P supposed to be solving? How much is it going to cost in extra forms and personnel to handle it and upgrades to the NFRTR? How long will it increase the wait time for 5320 forms?

    All to accomplish what, exactly?

    Nothing, other than to make it harder for US citizens to own firearms that shouldn’t even be regulated any differently anyway. NFA should have never been passed and it dang sure should have been overturned in 39!

  • WhoDatGrrl says:

    I wonder if they are waiting to see what happens with Hollis V Holder to figure out if legal entities are people or not. If so, it could get pushed back a LONG time. Unless they plan on resolving that quickly which I don’t think is likely.

  • Dan Sullivan says:

    I don’t know if they will ever make a decision on it. If they do make a decision then I don’t see how it could be pass it. To many problems with it for it to ever work in practice.

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