HARTFORD, CT – Yesterday, the Biden administration announced the final ruling for ATF 2021R-05, “Definition of ‘Frame or Receiver’ and Identification of Firearms.” Among its provisions, the ruling will effectively eliminate the distribution of “80% kits” and require FFLs and gunsmiths to serialize such firearms upon acquisition. The rule will go into effect 120 days from the date of publication in the Federal Register. The President also announced his nomination of Steve Dettelbach to serve as Director of ATF.
“This ruling will have significant regulatory and operational impacts on FFLs, gun owners and the entire firearms industry,” said Phil Milks, Orchid VP and Lead Attorney at FFL Law. “It’s imperative firearm manufacturers and retailers review the ruling in detail and evaluate their manufacturing, serialization and recordkeeping processes to ensure compliance when the new regulations go into effect. We urge FFLs to contact Orchid to learn more about this ruling and how it may affect their firearms business.”
Following the announcement, Orchid LLC and Williams Mullen’s Firearms Industry Group have organized a 90-minute discussion at the 2022 Firearms Industry Conference (FIC), to be held in Atlanta on April 26–27, in which ATF executives will review the new ruling and take moderated questions from conference attendees. Agency personnel will also be available during scheduled regulatory breakout sessions and private FFL/ATF meetings.
“With ATF executives in attendance, we believed it was important for attendees to have an opportunity to hear from and engage with their leadership in open dialogue,” said Orchid CEO, Jon Rydberg. “We’ve adjusted our schedule to allow for such discussion and encourage conference registrations to review the ruling and prepare questions in advance of the event.”
Over 20 ATF executives will attend FIC 2022, including:
– Marvin Richardson, Acting Director, ATF
– Tom Chittum, Acting Associate Deputy Director, ATF
– Andy Graham, Deputy Assistant Director, Office of Enforcement Programs & Services
– Marianna Mitchem, Chief, Firearms & Explosive Industry Division
– Curtis Gilbert, Deputy Assistant Director (Industry Operations), Office of Field Operations
– Andrew Lange, Chief, Office of Regulatory Affairs
“The Firearms Industry Conference is critically important, especially this year, to the firearms industry. We welcome the opportunity to provide a forum for the ATF leadership to speak with our attendees and to hear from industry leaders and market participants later this month,” said Chuck James, Co-Chair of the Williams Mullen Firearms Industry Group.
Held April 21–27, FIC 2022 features virtual and in-person educational sessions led by federal agency executives, firearms industry professionals and subject matter experts. Sessions are broken intro three comprehensive learning tracks: Firearms Industry Law & Finance, FFL Compliance, and FFL Technology. FIC On-Air™ will be held online April 21–22, followed by FIC Workshops on April 25 and the main FIC event on April 26–27 in Atlanta.
To register for or sponsor FIC 2022, visit orchidadvisors.com/FIC. A portion of all event registrations and sponsorships will be donated to Project ChildSafe. Attendees are encouraged to make hotel reservations at the Westin Buckhead Atlanta while vacancy remains.
Attending FFLs who wish to discuss confidential matters with the ATF should contact Marianna Mitchem at marianna.mitchem@atf.gov for availability.
About Orchid LLC
Orchid LLC and its family of companies, including partner firm FFL Law, have been offering business software, firearms-friendly payments, and legal and regulatory services to the shooting sports industry for over a decade. With powerful POS, ecommerce, ERP and Bound Book solutions, as well as expert knowledge of ATF, import/export and state-level regulations, Orchid helps FFLs profitably manufacture, distribute and sell firearms with great efficiency and the utmost compliance. Get started today at orchidadvisors.com.
About Williams Mullen
Williams Mullen is a regional, full-service law firm with offices across North Carolina, South Carolina and Virginia. The firm’s Firearms Industry Group helps industry members navigate legal issues from regulatory compliance to e-commerce development, financing needs and interest from the venture capital world. In addition, Williams Mullen attorneys provide advice and counsel in matters involving Import/Export Controls, White Collar & Investigations, Cybersecurity & Data Protection, Intellectual Property, Employment Law, Tax Law, Government Contracting and legal aspects of social media marketing. Learn how Williams Mullen can assist your company at williamsmullen.com.
About Project ChildSafe
NSSF, the trade association of the firearms industry, launched Project ChildSafe in 1999 (originally as Project HomeSafe). Since 1999, the program has provided more than 40 million free firearm safety kits and gun locks to firearm owners in all 50 states through partnerships with thousands of law enforcement agencies across the country. That’s in addition to the more than 70 million free locking devices manufacturers have included, and continue to include, with new firearms sold since 1998. While helping to prevent accidents among children is a focus, Project ChildSafe is intended to help adults practice greater firearm safety in the home. For more information, visit projectchildsafe.org.
