Comment on FR Doc # 2026-09159
Ed GreenSupportIndividual
Summary: The commenter, who serves as the chair of a local gun club's FFL committee, supports the rule defining "willfully" for firearms violations. They argue that honest clerical mistakes on Form 4473 should not result in criminal liability or the loss of an FFL license, while maintaining that intentional violations should still be prosecuted.
I strongly support this rule. My local gun club obtained an FFL so provide free delivery to members for online purchases, and I am chair of the FFL committee; I routinely transfer firearms to members and fill out Forms 4473. While this is not a complex form, it is long and can be confusing (not all questions apply to all transfers). An honest mistake, such as transposing digits, failing to check the right box, etc., should not threaten our FFL status and prevent us from providing this valuable service to our club members. Willful errors or omissions are illegal -- that action should of course be sanctioned and prosecuted if necessary. Simple (and in the vast majority of cases, harmless) mistakes by humans should not subject them to criminal liability, and should not threaten their club's/business's status as a licensee.