For those with interest in FFLs, and new illegal rules from ATF...
"For FFLs who maintain a sizeable inventory of any sort of firearms so as to provide customers with a selection, there has long been a concern that ATF may attempt to impose obligations to conduct periodic physical inventories in addition to the paper (or computerized) records of the Acquisition and Disposition (“A&D”) Books. Most FFLs conduct such inventories simply as a matter of good business practice. And when ATF conducts a periodic inspection it is routine to check serial numbers of all firearms in the inventory against the A&D record. The concern of FFLs is not so much with doing an inventory as with (1) the frequency of such an obligation as a physical inventory often means having to close the business for one or more days and (2) having yet more micro-regulation of the business that results in yet more traps to be sprung by over-zealous enforcement authorities.
Sensitive to such concerns, since 2004, Congress has included a provision in ATF’s annual appropriations prohibiting the expenditure of funds on the formulation or implementation of a regulation imposing any such obligation. Because the Government has been operating by continuing resolution after continuing resolution, it requires a bit of cross-reference to illustrate that the limitation remains effective. You can trust me or delve into this footnote.[1]
In light of that prohibition, it was rather surprising to see that the latest semi-annual regulatory agenda (RIN 1140-AA41) indicates that ATF plans to publish a proposed rule on that subject this very month, December 2013. Often entries in the regulatory agenda are little but wishful thinking so that entry alone might not be cause for concern but there is reason to believe the entry is more than fantasy."
http://blog.princelaw.com/2013/12/11...er-rulemaking/
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