RANGERRON72
03-12-2014, 08:29
From a customer who got this dealers newsletter from North Carolina.......... sorry its a long read, but worth it.......FWIW.
So let’s get right to the good news:
It appears that our long battle with ATF is coming to an end. They have already shipped out replacement tax stamps for the group of people who were affected by the mailing issue that I discussed in the last newsletter. We are working hard to notify people as soon as possible when we receive their tax stamp. For most of you, the issue ATF had with mailing the tax stamps has not affected your paperwork, but rather you are experiencing what has become the new normal – an 11 to 13 month wait from ATF.
Some more good news: As I’m sure some of you may have heard, the roll out of ATF 41P - the proposed rule change that may require a Sheriffs signature with a trust - has been delayed. That means that for all of you guys who made a purchase under the assumption that things were going to change BEFORE you got your suppressor, it looks as though you don’t have much to worry about for the foreseeable future. The latest reports are that ATF received more than 9,500 comments by the end of the official comment period, December 9, 2013. Approximately 1,000 of those comments were disqualified for a variety of reasons, including foul language and anonymity. That leaves around 8,500 comments that must be individually replied to. As of now, there has only been one individual at ATF assigned to reply to all of these comments. That individual has stated that it’s going to take a year or perhaps even two to reply to all of the comments. Based on this information we are confident that it will be business as usual for a while to come. Until we receive further notice of how the ATF 41P rule change might change the game, you can rest easy. So if you’ve been losing sleep at night thinking that you may have thrown your money down a rat-hole, no need to worry. Just roll over tonight and get some rest.
Now let’s talk about the E-File system. As most of you know, we have been using the E-File system almost exclusively now. When first introduced, the E-File system was billed as a new and “fast” way of getting approved for ownership of a silencer. That seemed like the case for those individuals who were lucky enough to go first, or unlucky enough to be the crash test dummies for the launch of the system, but it no longer seems that way. After talking with several of the other larger dealers around the country, and from feedback gained through conversations with ATF, it looks like the E-File application approvals are grinding to a halt. This is due in no small part to the massive technical glitches that continue to plague the E-File website and data servers. Over the last three months, the E-File system has gone from having one scheduled maintenance period each day at noon, to having four scheduled maintenance periods throughout the day, each one lasting an hour or so. When the system is actually online, it’s still incredibly slow, and extremely prone to errors and restarts. Very often, it can take the greater part of an hour to file one application. Along with the technical malfunctions, the system is constantly being bombarded with applications which only go to further increase system errors and delays. The ATF is reporting that well over 2,000 applications are submitted via the E-File system every week at this point. A large portion of these forms are not being filed for customers like yourself, but rather by manufacturers, dealers and law-enforcement, and this only serves to slow things down for regular guys buying suppressors.
As further proof that the ATF can do basically whatever they want since they control the process, we have learned that due to the SEVERE and widespread technical issues with the E-File website, ATF is shifting their focus back to paper forms. This has been verified by several other dealers we talk to across the country reporting that they are getting a large amount of tax stamps back over the last month or so. We can verify it ourselves as well, since the last two envelopes of tax stamps that we received back in the mail each had over 40 tax stamps in them; all from paper Forms we had submitted. I want to say this part as clearly as possible: Nobody on the face of God’s green earth wants you to have your suppressors and tax stamps back more than Hank and I do, but things can only go as fast as the current system will allow.
Regardless of what you may have read on the internet, or seen on tracking sites or heard from a shadowy figure standing in the back of your local gun shop, it looks like the E-File system is going to be slow hoeing, just as the now old fashioned paper applications have been for the last 80 years. We realize that things people read on the internet alter expectations, and we will always try our best to meet those expectations, but at some point we all have to be reasonable. That includes us too, as dealers. Sometimes I think we push ATF harder than we should for answers. And speaking for myself, I know that I personally spend more time than I would like working with ATF. I’ve sent countless emails, letters and phone calls over the past several years to ATF on your behalf.
ATF has little interest and incentive to help you get your suppressor quickly, so it will never be a fast process. They are just doing their job as dictated by Congress and the DOJ one day at a time. No matter how fast or efficient one rouge examiner might become, it won’t necessarily result in him or her getting a pay raise. There’s just no incentive for them to work harder to make our lives better. But of course you guys know this from your own personal experiences dealing with the government, whether it is the IRS or your local DMV office. It’s easy to see that when dealing with these organizations, in most cases they don’t care about you or your situation personally. You’re just a number on a spreadsheet or a form on their desk. Well it’s the exact same with ATF. And as we always say, buying a silencer is not like going down to the local Wal-Mart and buying a shotgun.
So let’s get right to the good news:
It appears that our long battle with ATF is coming to an end. They have already shipped out replacement tax stamps for the group of people who were affected by the mailing issue that I discussed in the last newsletter. We are working hard to notify people as soon as possible when we receive their tax stamp. For most of you, the issue ATF had with mailing the tax stamps has not affected your paperwork, but rather you are experiencing what has become the new normal – an 11 to 13 month wait from ATF.
Some more good news: As I’m sure some of you may have heard, the roll out of ATF 41P - the proposed rule change that may require a Sheriffs signature with a trust - has been delayed. That means that for all of you guys who made a purchase under the assumption that things were going to change BEFORE you got your suppressor, it looks as though you don’t have much to worry about for the foreseeable future. The latest reports are that ATF received more than 9,500 comments by the end of the official comment period, December 9, 2013. Approximately 1,000 of those comments were disqualified for a variety of reasons, including foul language and anonymity. That leaves around 8,500 comments that must be individually replied to. As of now, there has only been one individual at ATF assigned to reply to all of these comments. That individual has stated that it’s going to take a year or perhaps even two to reply to all of the comments. Based on this information we are confident that it will be business as usual for a while to come. Until we receive further notice of how the ATF 41P rule change might change the game, you can rest easy. So if you’ve been losing sleep at night thinking that you may have thrown your money down a rat-hole, no need to worry. Just roll over tonight and get some rest.
Now let’s talk about the E-File system. As most of you know, we have been using the E-File system almost exclusively now. When first introduced, the E-File system was billed as a new and “fast” way of getting approved for ownership of a silencer. That seemed like the case for those individuals who were lucky enough to go first, or unlucky enough to be the crash test dummies for the launch of the system, but it no longer seems that way. After talking with several of the other larger dealers around the country, and from feedback gained through conversations with ATF, it looks like the E-File application approvals are grinding to a halt. This is due in no small part to the massive technical glitches that continue to plague the E-File website and data servers. Over the last three months, the E-File system has gone from having one scheduled maintenance period each day at noon, to having four scheduled maintenance periods throughout the day, each one lasting an hour or so. When the system is actually online, it’s still incredibly slow, and extremely prone to errors and restarts. Very often, it can take the greater part of an hour to file one application. Along with the technical malfunctions, the system is constantly being bombarded with applications which only go to further increase system errors and delays. The ATF is reporting that well over 2,000 applications are submitted via the E-File system every week at this point. A large portion of these forms are not being filed for customers like yourself, but rather by manufacturers, dealers and law-enforcement, and this only serves to slow things down for regular guys buying suppressors.
As further proof that the ATF can do basically whatever they want since they control the process, we have learned that due to the SEVERE and widespread technical issues with the E-File website, ATF is shifting their focus back to paper forms. This has been verified by several other dealers we talk to across the country reporting that they are getting a large amount of tax stamps back over the last month or so. We can verify it ourselves as well, since the last two envelopes of tax stamps that we received back in the mail each had over 40 tax stamps in them; all from paper Forms we had submitted. I want to say this part as clearly as possible: Nobody on the face of God’s green earth wants you to have your suppressors and tax stamps back more than Hank and I do, but things can only go as fast as the current system will allow.
Regardless of what you may have read on the internet, or seen on tracking sites or heard from a shadowy figure standing in the back of your local gun shop, it looks like the E-File system is going to be slow hoeing, just as the now old fashioned paper applications have been for the last 80 years. We realize that things people read on the internet alter expectations, and we will always try our best to meet those expectations, but at some point we all have to be reasonable. That includes us too, as dealers. Sometimes I think we push ATF harder than we should for answers. And speaking for myself, I know that I personally spend more time than I would like working with ATF. I’ve sent countless emails, letters and phone calls over the past several years to ATF on your behalf.
ATF has little interest and incentive to help you get your suppressor quickly, so it will never be a fast process. They are just doing their job as dictated by Congress and the DOJ one day at a time. No matter how fast or efficient one rouge examiner might become, it won’t necessarily result in him or her getting a pay raise. There’s just no incentive for them to work harder to make our lives better. But of course you guys know this from your own personal experiences dealing with the government, whether it is the IRS or your local DMV office. It’s easy to see that when dealing with these organizations, in most cases they don’t care about you or your situation personally. You’re just a number on a spreadsheet or a form on their desk. Well it’s the exact same with ATF. And as we always say, buying a silencer is not like going down to the local Wal-Mart and buying a shotgun.