By John Brown
You’ve all heard the saying, “There is strength in numbers.” When those numbers organize, they can speak loudly and send a strong message. People acting collectively, including firearms owners and collectors, can make a difference. In the last issue of SAR, I said we would be introducing the newly organized association of NFA firearms importers, manufacturers, dealers, and collectors - the National Firearms Act Trade & Collectors Association (NFATCA) - and discussing its objectives, how these objectives can be achieved, and the mechanics of the new association. The effectiveness of any trade association requires that it be well-financed and well-connected. By “well-connected,” I mean, among other things, that it must work through legal and technical experts and people who know how to deal with the Government, including ATF and the Congress.
The Birth of NFATCA
About a year ago, John Brown from Battlefield Sports in Virginia started talking with other dealers about organizing “something” for our interests. We had a talk about what would happen if we put about 80 or so of the most influential and long-time Class III dealers into a room together with finger food and a choice of adult beverages. During the 2005 SHOT Show, we planned an event for Saturday night at Long Mountain Outfitters’ facility in Henderson, and it quickly grew into 135 attendees and the Chief of ATF’s NFA Branch as well as a number of other concerned government people who came and spoke with us. While the government people cannot endorse a group, the indication was that they would be very happy to have our input and to work with us towards solving issues in the NFA community. Our Firearms Attorney came and helped facilitate the meeting.
After hearing our discussions, it was decided by general consensus that we would start an activist trade organization, and John Tibbetts of John’s Guns, Teresa Starnes of J&T Distributing, and John Brown of Battlefield Sports volunteered to be the forming committee. The Las Vegas firm of Jones Vargas was hired to form a non-profit corporation in Nevada, and our Firearms Attorney was hired to do legal work with the group. We all filled in questionnaires to determine what common interests should dictate our initial agenda. A number of us immediately fired off $5,000 checks to get this group started and running. There have been many conference calls and meetings since then, and the newly formed trade association, the National Firearms Act Trade & Collectors Association has been born.
We had our first meeting on Wednesday before the April event at Knob Creek, with about 25 people attending and the NFATCA being the buzz all over the Knob Creek weekend. At the meeting, the Chief, NFA Branch, and a representative from TSA, spoke with the group. The ATF representative gave an encouraging talk on how we could work together to the betterment of all, and TSA briefed us on the problems in getting the TSA firearms transport policy information out to the gun owning public. The first Board of Directors was elected: Robert Landies of Ohio Ordnance LLC; Dan Shea of Long Mountain Outfitters LLC; John Brown of Battlefield Sports Ltd.; John Tibbetts of John’s Guns; and Teresa Starnes of Double Star Corp. Officers were also elected: President - John Brown; Vice President - John Tibbetts; Secretary-Treasurer - Teresa Starnes.
NFATCA’s Initial Agenda
One of our first priorities is the creation of an NFA manual similar to ATF’s Imports Handbook. The manual will set out ATF’s policies and procedures, to the extent ATF can legally share them with the public, regarding the importation, exportation, manufacture, and transfer of NFA firearms, as well as their legal rationale. Currently, these are a mystery to many members of the NFA community. Thus, the manual will make for a better informed NFA community, as well as educate ATF personnel responsible for processing NFA paperwork. The end results should be better compliance with the law and regulations and more efficient service by ATF.
While ATF might be able to produce a manual on its own at some future time, it may not have the budgetary resources to do so immediately. Since we believe that time is of the essence in this endeavor, we have proposed to enter into a memorandum of understanding with ATF for collaboration on writing the manual. Under this agreement, NFATCA’s attorneys and consultants will work with ATF to produce the document. Once finished, ATF will vet it out and our goal is to have an ATF-adopted manual published and in place by the end of 2005.
Based on the responses to the questionnaire distributed at LMO, other possible subjects on the agenda include:
- Streamlining the transfer process and developing procedures to address ATF’s loss of NFA filings.
- The possibility of establishing a system whereby collectors who are multiple purchasers can go through a 3-year “cleared” process so Forms 4 can be streamlined and expedited to them.
- Electronic submission of Forms 2, 3, and 5, Form 5320.20, and others.
- Establishing when a firearm “receiver” is an NFA firearm.
- Quality training for ATF examiners in the NFA Branch.
- Multiple post-1986 transfers from police departments to dealers in trades with police departments.
- Proper procedures to subcontract the manufacture of receivers or other restricted parts.
- Proper procedures for the manufacture, sale, and possession of suppressor parts by manufacturers, dealers, and individuals.
The proposed manual may address some of these issues. There are many more but too many to list in this short article. I also anticipate that the new association will provide invaluable service in giving the NFA community a “heads-up” on proposed legislation, regulations, and rulings affecting NFA firearms, as well as making timely comment on these matters on behalf of the association.
One very proactive thing that the NFATCA is working on is a special Dealer and Collector liability insurance policy program with Shoff Darby Companies. Allison Steeves from Shoff Darby has been the architect of a special liability plan for NFATCA to offer to members. To give you a general idea of the program, $1,000,000 per incident, $2,000,000 aggregate yearly policy coverage would cost an FFL Type 01 (including Class III) $1,400 per year. The same coverage for an FFL Type 03, Collector of Curios & Relics, is $500 per year, and both have only a $500 deductible. Also offered is a program for Class II manufacturers, based on a more complex formula according to sales, but it appeared to be very reasonable. The NFATCA is bringing insurance to the table because so many dealers have trouble getting insurance and many gun shows are legally required to have each displayer insured as well. (Please factor this insurance savings into your mental calculations when you read the dues section.)
Cost of Doing Business - the Dues
Many of us already pay legal and lobbying expenses. By combining these expenses at the organization level, we can achieve a more efficient and cost-effective use of our resources. Business members of the NFA community will recognize this savings immediately, as will collectors who can avail themselves of some inexpensive, quality liability insurance that is specific to firearms owners. Joining together can save all of us money. This is a fringe benefit. However, because the task at hand is exercising control of the destiny of the NFA community, that is going to require some serious money. That said, we have established a level of dues for the members, including a special “Plankholder” group. This group antes up the initial $5,000 Plankholder dues, and is the group that can elect the Board each year. By becoming a member of this group, you will know that you made a significant difference and that you have a say in where things in the NFA community are going because you put up the starting capital to get the NFATCA going. If you are in this business on a serious level, or if you are a collector with a serious commitment to NFA firearms ownership, then being a Plankholder is simply an exercise of enlightened self-interest. If you would like to join those of us who believe firmly in what we are doing here and want to send the $5,000, please call Teresa Starnes at (859) 745-1757. She will guide you through the process. The types of membership are as follows:
- Lifetime membership - Plankholder: $25,000. (You may pay in installments. Lifetime members pay no more dues, ever.)
- Plankholder: one time contribution of $5,000. (You may pay in installments. Plankholders need to pay yearly dues as Sponsor.)
- Sponsor membership: $1,000 per year.
- Dealer membership: $500 per year. (Same as your annual SOT.)
- Collector membership: $200 per year. (Same as one Form 4 transfer tax.)
You may also pay more than the yearly dues if you like. NFATCA is a bona fide non-profit trade organization. NFATCA membership policy requires proof of engagement in an NFA firearms business or responsibly pursuing NFA collecting in accord with all federal, state and local laws.
We hope you’ll join us in the new NFATCA. We believe we can accomplish great things together and would like to urge you to contact the Board member of your choice if you have questions, concerns, or issues that the Board should address.
We are in the process of setting up the contact points and a website. Please contact Teresa Starnes on how to join the NFATCA.
At the present time, the Board of Directors is limited to five members. We have two advisory seats specifically reserved for Plankholder members of the NFATCA who are only collectors, not licensed importers, manufacturers, or dealers. This would ensure that the voice of the collectors is always there with the Board. The Board members, officers, and other persons connected with NFATCA may be reached as follows:
Wednesday, October 12, 2005 before the October Knob Creek event, at the Holiday Inn off of the Fern Valley exit of I 65. Closed Board and Plankholder meeting will take place from 2:00 P.M to 4:00 P.M., and a meeting open to the public will occur from 4:00 P.M. to 7:00 P.M. You must register to attend.
Meeting during the SAR Phoenix Show in December 2005, to be announced.
Meeting during the SHOT Show in Las Vegas, Saturday night, February 11, 2006, at LMO LLC in Henderson. This is for NFATCA members only and attendees must register to attend.
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