NFATCA Posts comment to 41P

The NFATCA has posted a comment to 41p, requested a hearing and has some unusual arguments claiming must of the proposals and even some of the current procedure is not authorized by congress. IN addition, they have an interesting Legal Memorandum prepared by Stephen Halbrook that’s worth taking a look at.
His memo covers

I. NO AUTHORITY EXISTS TO REQUIRE FINGERPRINTS AND PHOTOGRAPHS OF “RESPONSIBLE PERSONS” OF TRUSTS AND OTHER ARTIFICIAL PERSONS
II. NO AUTHORITY EXISTS TO REQUIRE A CLEO CERTIFICATE FOR THE TRANSFER OR MAKING OF A FIREARM

• A. ATF, Not State and Local CLEOs, Is Responsible for Administration of the National Firearms Act
• B. The CLEO Requirement Unlawfully Forecloses Judicial Review Under the Administrative Procedure Act
• C. ATF May Not Compel Disclosure of Tax Returns to CLEOs
• D. The CLEO-Certificate Requirement Violates Principles of Federalism and the President’s Responsibility to Execute the Laws

I have included it on my 41P comment page available at https://www.guntrustlawyer.com/41p.html