Comment on FR Doc # 2026-09157

Comment on Docket No. ATF-2026-0266 Re: Proposed Revision of Non-Over-the-Counter Firearms Transaction Requirements I respectfully oppose the proposed rule allowing ordinary firearms to be shipped directly to purchasers without requiring an in-person transfer through a federally licensed firearms dealer (FFL). I submit this comment as both a citizen and as the Vice President of a federally licensed firearms retailer and shooting range in Tennessee. During my career, I have overseen thousands of firearm transfers, ATF compliance requirements, background checks, employee training, and daily FFL operations. My perspective comes from years of applying these regulations in real-world situations. While background checks are an important safeguard, they are only one part of a responsible firearm transfer. Every day, trained FFL employees verify identification, compare the purchaser to the ID presented, answer questions about ATF Form 4473, observe customer behavior, and identify circumstances that may indicate a straw purchase or other suspicious activity. We also have the authority—and responsibility—to refuse a transfer when something does not appear appropriate, even if a background check is approved. These decisions often rely on face-to-face interaction and professional judgment that cannot be replicated through remote identity verification or package delivery. The current system provides safeguards beyond simply determining whether someone is legally prohibited from possessing a firearm. It allows trained licensees to identify inconsistencies, ask follow-up questions, observe whether another individual appears to be directing the purchase, and ensure the person receiving the firearm is the actual purchaser. Eliminating the in-person transfer removes these important layers of accountability. The proposal also creates practical concerns that deserve careful consideration. Remote verification may make altered or stolen identification more difficult to detect. A video call cannot fully reveal whether another person is influencing the transaction outside the camera's view, and a delivery service cannot reasonably be expected to perform the same level of identity verification or evaluate suspicious circumstances that trained FFL employees routinely encounter. Local firearm dealers also provide an important public service beyond processing transfers. We educate first-time firearm owners, provide firearm safety instruction, maintain federally required records, invest heavily in regulatory compliance, work with law enforcement when appropriate, and serve as the final point of accountability before a firearm changes hands. Independent dealers have invested substantial resources in secure facilities, employee training, recordkeeping, and compliance systems specifically because Congress chose licensed dealers to fulfill this role. The proposal also has significant implications for small businesses. Local FFLs employ people in their communities, collect state and local taxes, support local economies, and provide services that large online retailers cannot. Customers visiting a local dealer often purchase ammunition, accessories, training, range memberships, and gunsmithing services while receiving professional guidance. Reducing customer traffic through local dealers would disproportionately affect independently owned businesses while shifting more sales toward large online retailers. I support modernization where it improves efficiency. Electronic records, improved technology, and streamlined administrative processes can benefit both dealers and consumers. However, modernization should not eliminate safeguards that continue to provide measurable value. The requirement that the final transfer occur in person before a licensed dealer preserves direct identity verification, professional judgment, chain of custody, and local accountability. These protections cannot be fully replaced through remote verification alone. For these reasons, I respectfully request that ATF withdraw this proposal or, at minimum, retain the requirement that the final transfer of a firearm occur in person through a federally licensed firearms dealer. Thank you for considering my comments and for the opportunity to participate in this rulemaking process.