Comment on FR Doc # 2026-09159

I support ATF's proposed rule clarifying when a state-issued firearms-related permit may qualify as an alternative to a separate National Instant Criminal Background Check System (NICS) check. The proposal appears to bring the regulations into closer alignment with the language enacted by Congress and should provide greater certainty to Federal Firearms Licensees and law-abiding firearm purchasers. Congress chose to create an exception allowing certain qualifying state permits to serve as an alternative to a separate background check. The role of the implementing regulations should be to faithfully carry out the statute as written. To the extent the proposed rule clarifies the statutory criteria and aligns regulatory language more closely with federal law, it promotes consistency, transparency, and respect for congressional intent. Clear regulations benefit both firearms dealers and the public. When the requirements are understandable and closely tied to the governing statute, compliance becomes easier and the likelihood of mistakes decreases. Ambiguous regulatory provisions can create unnecessary burdens for licensees and uncertainty for lawful purchasers. Clarifying the rules helps ensure that similarly situated individuals are treated consistently across jurisdictions. I also support efforts to avoid unnecessary duplication in the firearms transaction process. When a state has already conducted the investigation required for issuance of a qualifying firearms-related permit and Congress has authorized the use of such permits as an alternative to a separate NICS check, the regulations should not impose additional requirements beyond those contemplated by statute. Regulatory requirements should be tailored to the law enacted by Congress rather than expanded through administrative interpretation. The proposed rule also promotes federalism by recognizing the role of state permitting systems within the framework established by federal law. Where Congress has chosen to acknowledge qualifying state permits, the implementing regulations should provide a clear and workable path for their recognition. This approach respects both federal statutory requirements and the efforts states undertake in administering their own firearms permitting programs. Most importantly, this proposal appears to focus on clarifying existing law rather than creating new restrictions. Regulations are most effective when they accurately reflect statutory requirements and provide clear guidance to regulated parties. Aligning regulatory language with the governing statute helps ensure that citizens, dealers, and regulators are operating under the same understanding of the law. For these reasons, I support the proposed rule and encourage ATF to finalize it substantially as proposed.