giffords.org
AdvocacyOppose
Definition of "willfully"
Defining `Willfully' for Firearms Violations
ATF-2026-0265-0001NPRM
Comments
2,317
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 2,311 of 2,317 comments
100%· analysis in progress
Stance breakdown
+79%
Net support
Support2,047Oppose214Other50Not yet analyzed6
Aggregates include form-letter campaigns. Excluding them, net support is +20% across organic comments.
Who commented
Breakdown by commenter type.
Business
13
Individual
2,251
Trade association
3
Advocacy
36
Other
8
Not yet analyzed
6
Comments over time
Weekly arrivals, stacked by stance.
Posted May 8, 2026Deadline Aug 7, 2026
May 4May 25Jun 15Jun 29Jul 13Jul 27Aug 3
Support2,047Oppose214Other50
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"2,110
Mens rea requirements2,089
End zero-tolerance enforcement policy1,963
Zero-tolerance enforcement policy84
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 2,317 comments. 538 are organic, and 65 are still being processed for campaign detection.
Campaign1,714Organic538Not yet determined65
⚑
Protecting Firearms Dealers from Revocation
Organized by Gun Owners of America
60526.1% of total
Support
⚑
Defining Willfully for Firearms Violations
Organized by Gun Owners of America
49921.5% of total
Support
⚑
Support Meaningful Definition of Willfully
Organized by Gun Owners of America
37616.2% 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:
- Jul 8, 2026Big Boyz GunsSupportIndividual
The commenter, identifying as a law-abiding gun owner, supports the ATF's proposal to define "willfully" to distinguish between intentional violations and honest mistakes. They urge the agency to further strengthen the rule by requiring a finding of willfulness before initiating revocation proceedings, rejecting vicarious liability for employee errors, and accurately reflecting the high legal costs faced by dealers.
Read comment → - Jul 9, 2026Brooks MartinSupportIndividual
Brooks Martin, a private citizen and gun owner, supports the ATF's proposal to define "willfully" for firearms violations to protect law-abiding dealers from being penalized for honest mistakes. He urges the agency to further strengthen the rule by requiring a finding of willfulness before initiating revocation proceedings and rejecting strict liability for employee errors.
Read comment → - Jul 9, 2026Eric SeltzerSupportIndividual
The commenter, identifying as a law-abiding gun owner, supports the ATF's proposal to define "willfully" to distinguish between intentional violations and honest mistakes. They urge the agency to further strengthen the rule by requiring a finding of willfulness before initiating revocation proceedings, rejecting vicarious liability for employee errors, and accurately reflecting the high legal costs faced by dealers.
Read comment → - Jul 9, 2026Peter OgleSupportIndividual
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 argue that the current "zero tolerance" approach unfairly penalizes honest mistakes and request additional protections against strict liability and high costs of revocation proceedings.
Read comment → - Jul 9, 2026Kendall MillerSupportIndividual
The commenter, identifying as a law-abiding gun owner, supports the ATF's proposal to define "willfully" to distinguish between intentional violations and honest mistakes. They urge the agency to further strengthen the rule by requiring a finding of willfulness before initiating revocation proceedings, rejecting vicarious liability for employee errors, and accurately reflecting the high legal costs faced by dealers.
Read comment → - Jul 9, 2026R.W. GrossSupportIndividual
The commenter, identifying as a law-abiding gun owner, supports the ATF's proposal to define "willfully" to distinguish between intentional violations and honest mistakes. They urge the agency to further strengthen the rule by requiring a finding of willfulness before initiating revocation proceedings, rejecting vicarious liability for employee errors, and accurately reflecting the high legal costs faced by dealers.
Read comment → - Jul 9, 2026Anonymous AnonymousSupportIndividual
The commenter, identifying as a law-abiding gun owner, supports the ATF's proposal to define "willfully" to distinguish between intentional violations and honest mistakes. They urge the agency to further strengthen the rule by requiring a finding of willfulness before initiating revocation proceedings, rejecting vicarious liability for employee errors, and accurately reflecting the high legal costs faced by dealers.
Read comment → - Jul 9, 2026Keith ListSupportIndividual
The commenter, identifying as a law-abiding gun owner, supports the ATF's proposal to define "willfully" to distinguish between intentional violations and honest mistakes. They urge the agency to further strengthen the rule by requiring a finding of willfulness before initiating revocation proceedings, rejecting vicarious liability for employee errors, and accurately reflecting the high legal costs faced by dealers.
Read comment → - Jul 9, 2026Anonymous AnonymousSupportIndividual
The commenter, identifying as a law-abiding gun owner, supports the ATF's proposal to define "willfully" to distinguish between intentional violations and honest mistakes. They urge the agency to further strengthen the rule by requiring a finding of willfulness before initiating revocation proceedings, rejecting vicarious liability for employee errors, and accurately reflecting the high legal costs faced by dealers.
Read comment → - Jul 9, 2026Chris SmithSupportIndividual
The commenter, identifying as a law-abiding gun owner, supports the ATF's proposal to define "willfully" to distinguish between intentional violations and honest mistakes. They urge the agency to further strengthen the rule by requiring a finding of willfulness before initiating revocation proceedings, rejecting vicarious liability for employee errors, and accurately reflecting the high legal costs faced by dealers.
Read comment →