giffords.org
AdvocacyOppose
Definition of "willfully"
Defining `Willfully' for Firearms Violations
ATF-2026-0265-0001NPRM
Comments
2,310
Last activity Aug 3, 2026
Deadline
3 days
Closes Aug 7, 2026
Net supportiSupport minus oppose · campaigns included
+79%
+20% 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 2,306 of 2,310 comments
100%· analysis in progress
Stance breakdown
+79%
Net support
Support2,045Oppose213Other50Not yet analyzed4
Aggregates include form-letter campaigns. Excluding them, net support is +20% across organic comments.
Who commented
Breakdown by commenter type.
Business
13
Individual
2,248
Trade association
3
Advocacy
36
Other
8
Not yet analyzed
4
Comments over time
Weekly arrivals, stacked by stance.
Posted May 8, 2026Deadline Aug 7, 2026
May 4May 25Jun 15Jun 29Jul 13Jul 27Aug 3
Support2,045Oppose213Other50
Support × commenter type
How each type splits across stance.
Support
Oppose
Other
Individual
89%
9%
2%
Advocacy
67%
33%
0%
Business
77%
15%
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"2,108
Mens rea requirements2,087
End zero-tolerance enforcement policy1,962
Zero-tolerance enforcement policy83
Government overreach and agency accountability75
Second amendment rights44
Ffl regulatory burden29
Standard of willfulness for revocation28
Gun seller training requirements12
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.
1 organization filed this week — visible to subscribers.
| 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
13 organization-typed comments could not be identified.
Form letters
Campaigns
Organized form-letter drives, separated from organic one-off comments.
74%of comments arrived through 5 form-letter campaigns — 1,714 of 2,310 comments. 532 are organic, and 64 are still being processed for campaign detection.
Campaign1,714Organic532Not yet determined64
⚑
Protecting Firearms Dealers from Revocation
Organized by Gun Owners of America
60526.2% of total
Support
⚑
Defining Willfully for Firearms Violations
Organized by Gun Owners of America
49921.6% of total
Support
⚑
Support Meaningful Definition of Willfully
Organized by Gun Owners of America
37616.3% of total
Support
⚑
Defining "Willfully" for Firearms Violations
Organized by Gun Owners of America
1325.7% of total
Support
⚑
Defining "Willfully" for Firearms Violations
Organized by Gun Owners of America
1024.4% of total
Support
Comments
Explorer
Every mirrored comment — filter by stance, campaign, or issue.
Filter:
- 4 comments from the past week
4 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 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, 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 10, 2026Gun Owners of AmericaSupportIndividual
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 10, 2026A lilgun shoppeSupportIndividual
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 25, 2026Anonymous AnonymousSupportIndividual
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 25, 2026John LeafSupportIndividual
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 24, 2026Anonymous AnonymousSupportIndividual
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 23, 2026Trey LangfordSupportIndividual
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 23, 2026Robin StrandellSupportIndividual
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 →