giffords.org
AdvocacyOppose
Definition of "willfully"
Defining `Willfully' for Firearms Violations
ATF-2026-0265-0001NPRM
Comments
2,286
Last activity Aug 3, 2026
Deadline
3 days
Closes Aug 7, 2026
Net supportiSupport minus oppose · campaigns included
+81%
+23% 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 2,284 of 2,286 comments
100%· analysis in progress
Stance breakdown
+81%
Net support
Support2,039Oppose196Other49Not yet analyzed2
Aggregates include form-letter campaigns. Excluding them, net support is +23% across organic comments.
Who commented
Breakdown by commenter type.
Business
13
Individual
2,225
Trade association
3
Advocacy
35
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
Support2,039Oppose196Other49
Support × commenter type
How each type splits across stance.
Support
Oppose
Other
Individual
90%
8%
2%
Advocacy
69%
31%
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"2,088
Mens rea requirements2,067
End zero-tolerance enforcement policy1,953
Zero-tolerance enforcement policy79
Government overreach and agency accountability67
Second amendment rights43
Ffl regulatory burden29
Standard of willfulness for revocation26
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.
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
12 organization-typed comments could not be identified.
Form letters
Campaigns
Organized form-letter drives, separated from organic one-off comments.
75%of comments arrived through 5 form-letter campaigns — 1,714 of 2,286 comments. 508 are organic, and 64 are still being processed for campaign detection.
Campaign1,714Organic508Not yet determined64
⚑
Protecting Firearms Dealers from Revocation
Organized by Gun Owners of America
60526.5% of total
Support
⚑
Defining Willfully for Firearms Violations
Organized by Gun Owners of America
49921.8% of total
Support
⚑
Support Meaningful Definition of Willfully
Organized by Gun Owners of America
37616.4% 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:
- 2 comments from the past week
2 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 25, 2026R RaderSupportIndividual
The commenter supports the proposed rule to define "willfully" for firearms violations, arguing that the current zero-tolerance enforcement policy unfairly penalizes law-abiding gun dealers for honest clerical errors. They advocate for the rule to protect good-faith actors and restore access to firearms and services.
Read comment → - Jul 25, 2026Carolyn RogersSupportIndividual
The commenter supports the proposed rule to define "willfully" for firearms violations, arguing that the current zero-tolerance enforcement policy harms law-abiding gun dealers and reduces community access to firearms. They advocate for a standard that protects good-faith actors.
Read comment → - Jul 24, 2026Robert ParkSupportIndividual
The commenter supports the proposed rule to define "willfully" for firearms violations, arguing that the current zero-tolerance enforcement policy harms law-abiding gun dealers and reduces community access to firearms. They advocate for a standard that protects good-faith actors.
Read comment → - Jul 24, 2026Anonymous AnonymousSupportIndividual
The commenter supports the proposed rule because it clarifies how state-issued firearms permits can serve as alternatives to NICS checks, aligning regulations with congressional intent. They argue that the rule promotes consistency, reduces regulatory burdens for dealers, and respects federalism by recognizing state permitting systems.
Read comment → - Jul 24, 2026Anonymous AnonymousSupportIndividual
The commenter, a firearms dealer, supports the proposed rule to define "willfully" for firearms violations. They argue that the current zero-tolerance policy unfairly penalizes law-abiding dealers for minor clerical errors on Form 4473.
Read comment → - Jul 24, 2026Howard TurnerSupportIndividual
The commenter supports the proposed rule to define "willfully" for firearms violations. They argue that a consistent definition will help alleviate the administrative burden on small businesses and provide clarity for regulators and law enforcement.
Read comment → - Jul 24, 2026Clinton HallSupportIndividual
The commenter supports the proposed rule to define "willfully" for firearms violations, arguing that the current zero-tolerance enforcement policy unfairly penalizes law-abiding Federal Firearms Licensees (FFLs) for honest clerical errors. They advocate for a standard that protects good-faith actors from license revocation due to non-criminal mistakes.
Read comment → - Jul 24, 2026Ed GreenSupportIndividual
The commenter, who serves as the chair of a local gun club's FFL committee, supports the rule defining "willfully" for firearms violations. They argue that honest clerical mistakes on Form 4473 should not result in criminal liability or the loss of an FFL license, while maintaining that intentional violations should still be prosecuted.
Read comment → - Jul 18, 2026Ruth K NashSupportIndividual
The commenter supports the proposed action of defining "willfully" to close legal loopholes, arguing that gun sellers and their employees should face explicit penalties, such as loss of license or employment, for violating ATF laws and safety practices.
Read comment → - Jul 18, 2026James AddisonOtherIndividualRead comment →