giffords.org
AdvocacyOppose
Definition of "willfully"
Defining `Willfully' for Firearms Violations
ATF-2026-0265-0001NPRM
Comments
2,267
Last activity Aug 3, 2026
Deadline
3 days
Closes Aug 7, 2026
Net supportiSupport minus oppose · campaigns included
+82%
+26% excluding campaigns
Document
Details
The document's own metadata, straight from the source system.
- Title
- Defining `Willfully' for Firearms Violations
- Posted
- May 8, 2026
- Comment period
- May 8, 2026 – Aug 7, 2026
- FR Doc
- 2026-09159
- CFR
- 27 CFR Part 478
- Topics
Analysis
Overview
What the public is saying — stance, who's commenting, and the issues they raise.
Include campaigns
Analyzed 2,265 of 2,267 comments
100%· analysis in progress
Stance breakdown
+82%
Net support
Support2,036Oppose180Other49Not yet analyzed2
Aggregates include form-letter campaigns. Excluding them, net support is +26% across organic comments.
Who commented
Breakdown by commenter type.
Business
12
Individual
2,213
Trade association
3
Advocacy
29
Other
8
Not yet analyzed
2
Comments over time
Weekly arrivals, stacked by stance.
Posted May 8, 2026Deadline Aug 7, 2026
May 4May 25Jun 15Jun 29Jul 13Jul 27Aug 3
Support2,036Oppose180Other49
Support × commenter type
How each type splits across stance.
Support
Oppose
Other
Individual
90%
8%
2%
Advocacy
83%
17%
0%
Business
83%
8%
8%
Other
25%
25%
50%
Trade association
100%
0%
0%
Issues raised
The docket's canonical issues. Select one to browse its comments.
Definition of "willfully"2,073
Mens rea requirements2,051
End zero-tolerance enforcement policy1,950
Zero-tolerance enforcement policy77
Government overreach and agency accountability65
Second amendment rights42
Ffl regulatory burden29
Standard of willfulness for revocation19
Gun seller training requirements11
Gun seller liability4
Position map
Who stands where on each issue?
Every non-silent position is backed by an excerpt from the comment.
Issues shown
Uncheck an issue to choose another.
| Organization | Definition of "willfully" | End zero-tolerance enforcement policy | Mens rea requirements | Zero-tolerance enforcement policy | Ffl regulatory burden |
|---|---|---|---|---|---|
giffords.org AdvocacyOppose Giffords.org opposes the proposed rule because it defines "willful" violations too narrowly, which they argue provides g | · | · | · | · | |
Gun Owners of America (GOA) AdvocacySupport Gun Owners of America is urging its members to support the ATF's proposed rule defining "willfully" for firearms violati | · | ||||
National Rifle Association Trade associationSupport The National Rifle Association (NRA) supports the proposed rulemaking to codify a "willful" standard for firearms violat | · | · | |||
Silencer Central / BANISH Suppressors BusinessSupport The commenter, a CEO and founder of a firearms business (Silencer Central / BANISH Suppressors), supports the proposed r | · | · |
Gun Owners of America (GOA)
AdvocacySupport
Definition of "willfully"
End zero-tolerance enforcement policy
Mens rea requirements
Zero-tolerance enforcement policy
National Rifle Association
Trade associationSupport
Definition of "willfully"
End zero-tolerance enforcement policy
Mens rea requirements
Silencer Central / BANISH Suppressors
BusinessSupport
Definition of "willfully"
End zero-tolerance enforcement policy
Mens rea requirements
6 organization-typed comments could not be identified.
Form letters
Campaigns
Organized form-letter drives, separated from organic one-off comments.
76%of comments arrived through 5 form-letter campaigns — 1,714 of 2,267 comments. 489 are organic, and 64 are still being processed for campaign detection.
Campaign1,714Organic489Not yet determined64
⚑
Protecting Firearms Dealers from Revocation
Organized by Gun Owners of America
60526.7% of total
Support
⚑
Defining Willfully for Firearms Violations
Organized by Gun Owners of America
49922.0% of total
Support
⚑
Support Meaningful Definition of Willfully
Organized by Gun Owners of America
37616.6% of total
Support
⚑
Defining "Willfully" for Firearms Violations
Organized by Gun Owners of America
1325.8% of total
Support
⚑
Defining "Willfully" for Firearms Violations
Organized by Gun Owners of America
1024.5% of total
Support
Comments
Explorer
Every mirrored comment — filter by stance, campaign, or issue.
Filter:
- 32 comments from the past week
32 comments match your current view and arrived in the last week. Read this week's comments with stance, commenter type, and AI summaries on the paid plan.
- Jul 27, 2026Virginia Citizens Defense LeagueSupportIndividualRead comment →
- Jul 26, 2026B&T USAAnalysis pending📎 AttachmentRead comment →
- Jul 25, 2026Cool F/XSupportBusiness
A small federal firearms licensee supports the ATF's proposal to define "willfully" as intentional conduct with actual knowledge of its unlawfulness. The commenter argues that this distinction is necessary to protect conscientious businesses from losing their licenses due to inadvertent clerical errors or negligence.
Read comment → - Jul 24, 2026Trinity Arms LLCSupportBusiness
The commenter, a Federal Firearms Licensee (FFL), supports the proposed rule to define "willfully" for firearms violations. They argue that the current zero-tolerance policy unfairly penalizes law-abiding dealers for honest clerical mistakes and advocate for a standard that protects good-faith actors.
Read comment → - Jul 17, 2026Virginia Citizens Defense LeagueSupportIndividualRead comment →
- Jul 16, 2026TAP CUSTOM TACTICALSupportIndividual
The commenter, identifying as a law-abiding gun owner, supports the ATF's proposal to define "willfully" to require actual knowledge of unlawful conduct. They urge the agency to further strengthen the rule by requiring a finding of willfulness before initiating revocation proceedings, rejecting vicarious liability for employee mistakes, and accurately reflecting the high legal costs faced by dealers.
Read comment → - Jul 12, 2026National Firearms Act Trade and Collectors AssociationSupportTrade association
The National Firearms Act Trade and Collectors Association (NFATCA) supports the proposed amendments to clarify the definition of "willfully" in firearms license revocation proceedings. They argue that the proposal provides necessary transparency, consistency, and predictability for Federal Firearms Licensees while improving the organization and readability of the regulation.
Read comment → - Jul 12, 2026GOASupportIndividual
The commenter, identifying as a law-abiding gun owner, supports the ATF's proposal to define "willfully" to require actual knowledge of unlawful conduct. They urge the agency to further strengthen the rule by requiring a finding of willfulness before initiating revocation proceedings, rejecting vicarious liability for employee mistakes, and accurately reflecting the high legal costs faced by dealers.
Read comment → - Jul 12, 2026Big Ds AutoSupportIndividual
The commenter, identifying as a law-abiding gun owner, supports the ATF's proposal to define "willfully" to require actual knowledge of unlawful conduct. They urge the agency to further strengthen the rule by requiring a finding of willfulness before initiating revocation proceedings, rejecting vicarious liability for employee mistakes, and accurately reflecting the high legal costs faced by dealers.
Read comment → - Jul 11, 2026Eastern Sky ArmsSupportBusiness
A Federal Firearms Licensee (FFL) supports the effort to define "willfully" but urges the Bureau to include specific safeguards. The commenter argues that the ATF must establish willfulness before initiating revocation proceedings, reject strict liability for employee mistakes, and more accurately account for the high legal costs of defending against such actions.
Read comment →