While the NRA’s comment is only 17 pages it incorporates many comments and references many including mine. On page one of the NRA’s comment they state
Many Hundreds of comments already published in opposition to 41P exhaustively catalog its various problems and potential for absurd consequences. For example, a comment submitted by David M. Goldman details how 41P is based on an unsophisticated and inaccurate view of the law governing trusts and estate planning.
The NRA’s comment primarily leads with the following 3 issues.
- It is illegal for the BATFE to impose requirements that it is not authorized to do.
- The requirements could block those who are lawfully entitled to possess NFA firearms from doing so.
- ATF failed to justify the costly and consequential changes that 41P would pose.
To review the full comment please see my 41P comment page.
*[I have slightly modified that the NRA states as the Florida Bar as well as many other reserve the word specialize or expert for someone who has been board certified and while most states offer board certification in estate law, none offers such a designation for gun law. While I focus on Gun Trust and gun law, it would be wrong to refer to me an expert or to say I specialize because it would indicate board certification.]