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Firearms Industry Consulting Group®

Challenging Bump Stock Rulemaking

As many of our clients and viewers are aware, Firearms Industry Consulting Group® (FICG®) a division of Civil Rights Defense Firm, P.C., has submitted substantial comments in opposition to rulemaking entered into by the Bureau of Alcohol, Tobacco, Firearms and Explosives and spearheaded the opposition to ATF-41P. Unfortunately, as it appears that ATF intends to move forward expeditously with a proposed rule in relation to bump stocks (and potentially other firearm accessories which purportedly permit or result in higher cyclic rates by the operator), we’re asking for your support so that we can prepare a comprehensive comment with appropriate expert reports, so that if ATF enacts any form of regulation, we will be able to challenge it in court.


<p “=””>Although the ATF previously issued an advance notice of proposed rulemaking in relation to bump stocks, the purpose was to gather limited information so that ATF could formulate a proposed rule. For more information, please see our article: ATF to Publish Advance Notice of Proposed Rulemaking Re: Application of the Definition of Machinegun to “Bump Fire” Stocks and Other Similar Devices. Given the President’s Memorandum directing ATF to move forward, expeditiously, with rulemaking, and his comments on February 26th that he will move forward to regulate bump stocks absent Congressional action, we anticipate a proposed rule in the near future. <p “=””>Spearheading the Opposition to a Bump Stock Proposed Rule – ATF 2017R-22 <p “=””>On March 23, 2018, a 55 page draft version of the the proposed regulation on bump stocks was published, which would make unlawful the possession of bump stocks and lacks any just compensation for the require destruction of those bump stocks and other similar devices, which are currently, lawfully owned. There are also concerns as to whether the language proposed by ATF could impact competition triggers and other tangentially related parts and accessories. Thus, it is imperative that we begin retaining experts to provide expert opinion on functionality of bump stocks. We also must begin formulating all arguments in opposition, so that we can ensure that all issues can later be raised in court, if necessary. To keep our viewers apprised of all updates, we have also created the Facebook page – Americans Opposed to ATF 2017R-22. <p “=””>As is demonstrated by our Comment and Supplemental Comment to ATF-41P, our attorneys have the necessary experience and understanding of the issues surrounding Administrative Law, the Gun Control Act and the National Firearms Act to ensure that any comment is properly and thorough prepared. The costs to retain experts and prepare a proper and thorough comment are substantial and unfortunately, we can’t do it without your support. Unlike the Government, we don’t have unlimited funds at our disposal. <p “=””>We are therefore requesting donations to fund the preparation of a comment in opposition. All donations will be held in our trust account and the money in trust will only be billed against, as work is performed or costs incurred in relation to this matter.

Anyone wishing to donate can:

  • Pay via our secure website: Civil Rights Defense Firm, P.C. – Please place “Bump Stock Regulation” in the reference field
  • Mail donations to: Civil Rights Defense Firm, P.C., 646 Lenape Rd, Bechtelsville, PA 19505; or,
  • Call our office at 888-202-9297.

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<p “=””>When submitting your donation, please include a note or inform the staff that you are donating in relation to the Bump Stock Regulation. <p “=””>Want to Stay Up To Date? <p “=””>Like our Facebook page – Americans Opposed to ATF 2017R-22 – and make sure to click “See First” under the Following tab, so that you can be kept apprised of all new developments! <p “=””>Disclaimer – Submission of a donation does not create an attorney-client relationship. By submitting any donation, you understand and agree that no attorney-client relationship is formed and that neither Civil Rights Defense Firm, P.C. nor any of its divisions or attorneys have agreed or are obligated to represent you or provide you with any legal advice. <p “=””>If you are interested in seeing the depth of a proper comment and our prior work, please see the comments we drafted in relation to ATF-41P: <p “=””>Initial 500+ page Comment

Supplemental Comment

Goldman/ Comment

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