Defining `Willfully' for Firearms Violations

The commenter supports the ATF's proposal to define "willfully" for firearms violations, arguing that the previous "zero tolerance" approach unfairly penalized 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 accounting for the high legal costs faced by dealers.

The commenter supports the ATF's proposal to define "willfully" for firearms violations, arguing that the previous "zero tolerance" approach unfairly penalized 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 accounting for the high legal costs faced by dealers.

The commenter supports the ATF's proposal to define "willfully" for firearms violations, arguing that the previous "zero tolerance" approach unfairly penalized 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 accounting for the high legal costs faced by dealers.

The commenter supports the ATF's proposal to define "willfully" for firearms violations, arguing that the previous "zero tolerance" approach unfairly penalized 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 accounting for the high legal costs faced by dealers.

The commenter supports the ATF's proposal to define "willfully" for firearms violations, arguing that the previous "zero tolerance" approach unfairly penalized 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 accounting for the high legal costs faced by dealers.

The commenter supports the ATF's proposal to define "willfully" for firearms violations, arguing that the previous "zero tolerance" approach unfairly penalized 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 accounting for the high legal costs faced by dealers.

The commenter supports the ATF's proposal to define "willfully" for firearms violations, arguing that the previous "zero tolerance" approach unfairly penalized 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 accounting for the high legal costs faced by dealers.

The commenter supports the ATF's proposal to define "willfully" for firearms violations, arguing that the previous "zero tolerance" approach unfairly penalized 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 accounting for the high legal costs faced by dealers.

The commenter supports the ATF's proposal to define "willfully" for firearms violations, arguing that the previous "zero tolerance" approach unfairly penalized 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 accounting for the high legal costs faced by dealers.

The commenter supports the ATF's proposal to define "willfully" for firearms violations, arguing it protects law-abiding dealers from being penalized for honest mistakes. They urge the agency to ensure willfulness is established before initiating revocation proceedings, reject vicarious liability for employee errors, and more accurately account for the high legal costs of such proceedings.