Everytown Comments on Multiple Rifle Sales and Gun Trafficking

In this comment to ATF, Everytown for Gun Safety urged the agency to require federally licensed gun dealers in all 50 states to report when any individual buys multiple rifles meeting certain criteria within a period of five business days, because such reporting is critical to investigating drug and gun trafficking and stopping organized crime.

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June 16, 2014
SUBMITTED VIA E-MAIL
Ms. Natisha Taylor
United States Department of Justice
Bureau of Alcohol, Tobacco, Firearms and Explosives
99 New York Avenue NE
Washington, D.C. 20226
[email protected]
Re: Comments of Everytown for Gun Safety on OMB Number 1140-0100: Agency
Information Collection Activities; Proposed eCollection; Report of Multiple Sale or
Other Disposition of Certain Rifles, 79 Fed. Reg. 72 (filed April 15, 2014)
Dear Ms. Taylor:
Everytown for Gun Safety (“Everytown”), a national, bipartisan coalition of mayors, moms, law
enforcement officials, survivors, and everyday Americans and the country’s largest gun violence
prevention advocacy group, submits these comments on the United States Department of Justice
(the “Department”), Bureau of Alcohol, Tobacco, Firearms and Explosives’ (the “Bureau”)
Notice of Agency Information Collection Activities, which proposes to extend the requirement
that federal firearms licensees in the four American states bordering Mexico report when any
individual buys multiple rifles meeting certain criteria within a period of five business days.
Reporting such multiple sales has been critical to investigating gun and drug trafficking and
stopping organized crime. Indeed, as gun trafficking is a national problem, the Bureau should
consider extending this reporting requirement to dealers in all 50 states.
For many years, Mayors Against Illegal Guns (“MAIG”), a bipartisan coalition of 1,000 current
and former mayors (which merged with Moms Demand Action in 2014 to form Everytown), has
engaged in research on the national problem of gun trafficking. In September 2010, MAIG
released a report analyzing trace data and finding a link between the strength of state gun laws
and the likelihood that guns (1) will be exported to another state for use in a crime and (2) will
move quickly from retail sale to recovery at a crime scene—a key indicator of trafficking known
as “time to crime.”1
This report is attached to these comments as Exhibit A. The report advocated

1 MAYORS AGAINST ILLEGAL GUNS, Trace the Guns: The Link Between Gun Laws and Interstate Gun Trafficking
(September 2010) (attached as Exhibit A). Additional and updated research is also available at
http://www.tracetheguns.org/.
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for common-sense gun laws that would impact gun trafficking, including inspections and proper
record keeping for licensed firearms dealers.
Recognizing the key role that multiple sales play in gun trafficking crime, MAIG proposed in
2009 that the Bureau extend the requirement that dealers report multiple sales of handguns to
include multiple sales of certain long guns by some dealers.
2 MAIG’s proposal was the basis for
the long gun multiple sales reporting initiated by the Department in 2010-2011—which is that is
the subject of this Notice. Further, MAIG and Everytown have advocated for federal legislation
to make trafficking a federal crime and to increase penalties for trafficking kingpins,
3
and have
pressed Congress to repeal a budget rider that prevent the Bureau from requiring dealers to report
on their inventories.
Requiring that federally licensed dealers report multiple sales or dispositions of certain long guns
provides an invaluable tool for law enforcement to stop violent gun-related crime and break up
trafficking rings. Recognizing the critical importance of this tool and the national dimensions of
trafficking, the Department should not only renew multiple sales reporting in Arizona,
California, New Mexico, and Texas, but should also extend the requirement to dealers in all 50
states.
1. For Nearly 40 Years, Dealers Have Been Required by Federal Regulation and
Statute to Report Multiple Sales of Handguns to the Bureau.
Since 1975, all federally licensed firearms dealers have been required to report multiple handgun
purchases by a single purchaser within a period of five business days.4
This reporting
requirement for handguns is intended to help “monitor and deter illegal interstate commerce in
pistols and revolvers.”
5 According to a report by the Government Accountability Office
(“GAO”), this “federal reporting requirement was established to cover multiple sales of
handguns, following studies showing that handguns sold in multiple sales to the same individual
purchaser were frequently used in crime.”6
In August 2011, the Bureau began a program requiring licensed dealers in the four southwest
border states—Arizona, California, New Mexico, and Texas—to report when any individual
buys two or more rifles that meet certain criteria within a period of five business days.7
This

2 MAYORS AGAINST ILLEGAL GUNS, A Blueprint for Federal Action on Illegal Guns: Regulation, Enforcement, and
Best Practices to Combat Illegal Gun Trafficking (August 2009) at 30-31 available at http://bit.ly/UFXcu0.
3 MAIG and Everytown support the passage of Senate Bill 53, the Stop Illegal Trafficking in Firearms Act of 2013,
which would make trafficking a federal crime and would address “straw purchasing” situations in which one
individual purchases a gun on behalf of another.
4
27 C.F.R. § 178.126(a) (1975) (requiring reporting by regulation); Firearm Owners’ Protection Act, 18 U.S.C. §
923(g)(3)(1986) (requiring reporting by statute).
5
40 Fed. Reg. 19201 (May 2, 1975).
6 UNITED STATES GOVERNMENT ACCOUNTABILITY OFFICE, Firearms Trafficking: U.S. Efforts to Combat Arms
Trafficking to Mexico Face Planning and Coordination Challenges (June 2009), at 28, available at
http://1.usa.gov/1pB1z69 [hereinafter Firearms Trafficking].
7
76 Fed. Reg. 83 (April 29, 2011).
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program, sometimes known as the “Demand Letter 3” program, requires reporting for multiple
sales of all semiautomatic rifles having a caliber greater than .22 and with the ability to accept
detachable magazines.8
The Bureau issued this requirement under its 18 U.S.C. § 923(g)(5)
“demand letter” authority, which authority requires federally licensed dealers to submit any
information required to be kept by law, if and to the extent submission is required by written
letter from the Bureau.
2. The Current Multiple Sales Reporting Requirement for Handguns, and for
Certain Rifles under Demand Letter 3, Helps Law Enforcement to Stop Crime.
Since it began in 2011, the Demand Letter 3 program has generated thousands of reports from
dealers and has assisted the Bureau and law enforcement officials in protecting the public from
gun-related crime.
a. Multiple Firearm Sales Are a Marker for Trafficking and for Subsequent
Use in Violent Crime.
The Bureau has stated that multiple sales of firearms are a “significant indicator” for gun
trafficking. 9 Multiple sales are a common feature of major gun trafficking prosecutions as well:
In one case where a trafficking ring purchased at least 251 rifles or shotguns over a 16-month
period, all but one of those weapons was purchased as part of a multiple sale.10
The Bureau’s research into gun tracing data also shows that more than one in five handguns
recovered at crime scenes in 32 examined cities were originally purchased as part of a multiple
sale.11 A similar study found that handguns bought in multiple sales in Maryland were 64 percent
more likely to be used in crime than other Maryland handguns, and that one in four handguns
bought in Maryland and subsequently recovered at crime scenes had been sold as part of a
multiple sale.12 That study also showed that recovered guns that had been sold in multiple sales
had a shorter time to crime than other guns, suggesting a nexus between multiple sales and
trafficking. The Maryland study identified the purchase of multiple guns as a “promising
intervention point[] for reducing the flow of guns into illicit markets.” 13 Another national study

8 ATF FACT SHEET: MULTIPLE SALES REPORTING FOR CERTAIN RIFLES REPORTING, available at
http://1.usa.gov/1lsqCk5.
9 Firearms Trafficking, supra note 6, at 28.
10U.S. DEPARTMENT OF JUSTICE, OFFICE OF THE INSPECTOR GENERAL, EVALUATION AND INSPECTIONS DIVISION,
Review of ATF’s Project Gunrunner (November 2010) at 38, available at http://1.usa.gov/1y9zghy [hereinafter
Review of ATF’s Project Gunrunner].
11 DEPARTMENT OF THE TREASURY, BUREAU OF ALCOHOL, TOBACCO AND FIREARMS Youth Crime Gun Interdiction
Initiative (November 2000), at § 2-8, available at http://1.usa.gov/1pBoEFP; see also DEPARTMENT OF THE
TREASURY, BUREAU OF ALCOHOL, TOBACCO AND FIREARMS, Youth Crime Gun Interdiction Initiative (July 2002), at
§ 2-9, http://1.usa.gov/1p91THE.
12 Christopher S. Koper, Crime Gun Risk Factors: Buyer, Seller, Firearm, and Transaction Characteristics
Associated with Gun Trafficking and Criminal Gun Use, JERRY LEE CENTER OF CRIMINOLOGY, UNIV. OF
PENNSYLVANIA (2007), available at http://1.usa.gov/1qWcXa9.
13See id. at 7.
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similarly concluded that guns sold by those dealers who make a high number of multiple sales
are more likely to have a short time to crime.
14
b. The Multiple Sales Reporting Requirement Gives the Bureau and Law
Enforcement Officials a Mechanism to Track Guns Quickly and Is a Critical
Tool for Criminal Investigations.
The Bureau reported in 2000 that it had initiated 205 investigations based on reviews of multiple
handgun sales reports, representing 13 percent of all Bureau criminal trafficking investigations.
15
In practice, both Bureau headquarters and the National Tracing Center send multiple sales
reporting data to Bureau field offices, and field offices use that data to uncover trafficking
patterns in the regions where they have expertise. The Bureau may look for a variety of
indicators from those multiple sales, including purchasers with a history of connections to guns
used in crimes or who have been linked to more than one multiple sale. A report by the
Department of Justice, Office of Inspector General (“OIG”) confirms that “reports of multiple
sales of handguns produce timely, actionable investigative leads for ATF.”16
When law enforcement traces a handgun recovered at a crime scene, the trace is faster and more
efficient if the gun was purchased in a multiple sale, giving law enforcement a critical advantage
in catching potentially violent criminals.17 In a trace, the Bureau queries the serial number of the
recovered firearm; if the gun was purchased in a multiple sale, the Bureau can use the dealer
report produced by the sale (and already submitted to the Bureau) to identify the retail purchaser
immediately. If the gun was not purchased in a multiple sale and reported as such, the Bureau
will only be able to trace the gun by contacting the manufacturer and then the wholesaler to
identify the retailer who first sold the gun to an unlicensed person. The Bureau must then contact
the retailer to determine the first retail purchaser.
According to an OIG report on the Bureau’s programs, if a traced crime gun is connected to
multiple sales reporting information, the trace “can be completed in minutes rather than days or
weeks.”18 The National Tracing Center staff estimates that a trace not linked to such reporting
takes 7 to 10 days to complete,19 and the Bureau has said it takes an average of 14 days to
complete a trace of a crime gun recovered in Mexico.
20 Leads generated from trace results “are
most useful within the first few days following a firearm seizure,” as trafficking rings are fast-

14 Anthony Braga et al., Characteristics and Dynamics of Crime Gun Markets: Implications for Supply-Side
Focused Enforcement Strategies, NATIONAL INSTITUTE OF JUSTICE (September 2003), available at
http://1.usa.gov/1pBihT4.
15 U.S. DEPARTMENT OF TREASURY, BUREAU OF ALCOHOL, TOBACCO, FIREARMS, AND EXPLOSIVES, Following the
Gun: Enforcing Federal Law Against Firearms Traffickers (June 2000), at 9, tbl. 1 (2000), available at
http://bit.ly/1i4Wlxr.
16 Review of ATF’s Project Gunrunner, supra note 10, at 39.
17 Firearms Trafficking, supra note 7, at 28 (“officials noted the federal multiple sale reporting requirement helps
expedite the time required by ATF to complete a crime gun trace”).
18 Review of ATF’s Project Gunrunner, supra note 10, at 37.
19 Id.
20 Firearms Trafficking, supra note 6, at 25-26
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moving and change personnel frequently.21 Thus, multiple sales reporting provides the Bureau
with important data at the moment when such information is most critical to the investigation
and to prevention of future crimes. Without that information, law enforcement may miss critical
leads and the trail of a criminal may run cold.
The same logic that supports the nearly 40-year-old reporting requirement for multiple handgun
sales applies equally to a long gun reporting requirement. Indeed, the OIG found that long guns
have a shorter time to crime than handguns, and noted that the percentage of crime guns
recovered in Mexico that are long guns increased several years in a row before the southwest
reporting rule was introduced.
22
c. The Current Long Gun Reporting Program Has Played a Significant Role in
Helping the Bureau to Prevent Gun Trafficking Along the Border, Where
Long Guns Are Commonly Used by Mexican Cartels to Commit Violent
Crimes.
The long gun reporting requirement has helped law enforcement crack down on gun trafficking,
particularly along the southwest border. Before the Demand Letter 3 program was implemented,
an OIG study found that the lack of reporting of multiple purchases of long guns “hinders ATF’s
ability to disrupt the flow of illegal weapons into Mexico.”23 And once the program was in place,
its effect was seen immediately: During its first eight months,
24 the program generated more than
3,000 reports from the four border states, which accounted for the purchase of more than 7,300
rifles.25 The Bureau opened more than 120 criminal investigations based on these multiple rifle
sales reports alone, and prosecution was ultimately recommended for over 100 defendants.26
The semi-automatic rifles subject to the Demand Letter 3 reporting program are especially likely
to be used by traffickers, and these long guns disproportionately fuel Mexican cartel violence.
Between December 2006 and September 2011, these drug gangs reportedly killed more than
47,000 people in Mexico, including thousands of police and military personnel.27 According to
the Department, “long guns have become Mexican cartels’ weapons of choice.”28 Indeed, the
Bureau’s assistant director for field operations testified to Congress that drug traffickers no
longer favor handguns, but rather “have developed a preference for higher quality more powerful

21 Firearms Trafficking, supra note 6, at 26.
22 Review of ATF’s Project Gunrunner, supra note 10, at 38.
23 Review of ATF’s Project Gunrunner, supra note 10, at iv.
24 from mid-August 2011 through mid-April 2012
25 ATF Fact Sheet: Multiple Sales Reporting Analysis, BUREAU OF ALCOHOL, TOBACCO, FIREARMS AND EXPLOSIVES
(May 4, 2012), available at http://1.usa.gov/1i1BVVN.
26 See id.
27 47,000 People Killed in Drug Violence in Mexico, ASSOCIATED PRESS (Jan. 11, 2012), available at
http://fxn.ws/1q0Prcn .
28 Review of ATF’s Project Gunrunner, supra note 10, at 36.
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weapons”—especially rifles with larger calibers.
29 There has been a concomitant decrease in the
use of handguns by these cartels.
30
Long guns recovered in crimes in Mexico are also more likely to have a short time to crime,
further indicating their prevalence in trafficking.31 In one case, 251 out of 336 guns purchased in
the United States by one Mexican cartel over 16 months (in a total of 96 purchases) were long
guns. One individual prosecuted as a result of that investigation had purchased firearms linked to
eight different murders in Mexico. According to the OIG, the investigation into that cartel could
have begun at least a year earlier—if only a long gun multiple sales reporting requirement had
been in place at the time of the purchases.
32
Rifles like the ones subject to Demand Letter 3 reporting—including 7.62 mm AK-type rifles
and .223 caliber AR-15 type rifles, which are among the firearms recovered most frequently in
Mexico33—are commonly paired with high-capacity magazines. When assault weapons and
high-capacity magazines are used in mass shootings, they consistently kill more people. In an
analysis of mass shootings between January 2009 and September 2013, MAIG reported that
when assault weapons and high-capacity magazines are used in mass shootings, 151 percent
more people are shot and 63 percent more people are killed.
34 Simply put, violent crime is more
deadly when these weapons are used.
In sum, there is ample evidence establishing multiple firearm sales as a marker of gun trafficking
and subsequent use in violent crimes, and showing that access to records from these sales helps
law enforcement to disrupt trafficking. As discussed below, the Bureau should continue the
requirement that licensed firearms dealers in the four border states report multiple long gun sales
and should consider requiring the same reports from licensed firearms dealers in all 50 states.
3. The Bureau Is Clearly Empowered to Require Dealer Reporting of Multiple Long
Gun Sales in the Four Border States and Should Continue to Do So.
As the Bureau is considering extending the multiple sales reporting requiring for the four border
states, it is significant to note that every federal court that has addressed the issue has found that
requiring dealers in those states to report multiple long gun sales is well within the Bureau’s
regulatory power under the demand letter authority set forth in 18 U.S.C. § 923(g)(5).
In May 2013, a three-judge panel of the U.S. Court of Appeals for the D.C. Circuit unanimously
held that federal law “unambiguously authorizes” the Demand Letter 3 program, upholding a

29 Law Enforcement Responses to Mexican Drug Cartels: Hearing Before the S. Comm. on the Judiciary and S.
Subcomm. on Crime and Drugs (March 17, 2009) (statement of William Hoover, Assistant Director for Field
Operations, Bureau of Alcohol, Tobacco, Firearms and Explosives, U.S. Department of Justice).
30 Firearms Trafficking, supra note 6, at 17.
31 Review of ATF’s Project Gunrunner, supra note 10, at 39.
32 Id.
33 Firearms Trafficking, supra note 6, at 17.
34 Analysis of Recent Mass Shootings (Sept. 2013), at 3, available at http://bit.ly/R5K9zi.
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prior decision in the district court.35 Then, in July 2013, a unanimous panel of the U.S. Court of
Appeals for the Fifth Circuit adopted the D.C. Circuit’s finding that federal law “unambiguously
authorizes the demand letter,” affirming another district court decision.
36 A March 2013 opinion
from the U.S. District Court for the District of New Mexico also held that the Demand Letter 3
program was within the Bureau’s authority.37
4. The Bureau Should Extend the Long Gun Multiple Sales Reporting Requirement to
All Fifty States to Reflect the National Scope of Gun Trafficking.
Everytown strongly urges the Bureau to consider requiring federally licensed dealers across the
United States to report multiple sales of these rifles, given the effectiveness of the current
reporting program in the four southwest border states to date and the inherently nationwide threat
posed by gun trafficking. Just as the handgun multiple sales reporting requirement applies to
dealers throughout the country, the Bureau should require the reporting of the same information
for covered long guns.
a. Trafficking Is a Problem With National Dimensions.
Trafficking is a national problem that cannot be solved by a single state’s legislators and law
enforcement, and cannot be solved by focusing on the four border state sales alone.
As MAIG’s Trace the Guns report documented, trafficking is a problem throughout the country.
Indeed, while states with significant dealer regulations—requiring sales reporting and subjecting
dealers to inspection—do export fewer crime guns, they are at the mercy of the weaker controls
of their neighbors, which may provide traffickers with easy access to guns. Trace the Guns
demonstrated that in 2009 ten states supplied nearly half—49 percent—of all crime guns
recovered outside of the state where they were sold.38 Conversely, New York City has some of
the strongest gun laws in the country, and 90 percent of all crime guns recovered in the city were
first purchased outside of the state.39
The Bureau considers crime guns traced to out-of-state multiple sales to be an indicator of
trafficking—further evidence that trafficking is a national problem. Additionally, a study of
Maryland crime guns indicated specifically the role played by cross-state multiple sales:
“[M]ultiple sales are an important mechanism for the trafficking of guns from jurisdictions with
more lenient gun controls to those with more stringent gun controls.”40

35 Nat’l Shooting Sports Found., Inc. v. Jones, 716 F.3d 200, 208 (D.C. Cir. 2013).
36 10 Ring Precision, Inc. et al. v. Jones, 722 F.3d 711, 718 (5th Cir. 2013).
37 Ron Peterson Firearms v. Jones, 11-CV-678 (D.N.M. 2013).
38 Exhibit A, at 2.
39 “Mayor Bloomberg, Police Commissioner Kelly And Criminal Justice Coordinator Feinblatt Release New Data
Showing Increase In Percentage Of Out-of-state Guns Used To Commit Crimes In New York City,” Nyc.gov (July
31, 2013), available at http://on.nyc.gov/1lpXdgi
40 Koper, supra note 12, at 76.
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According to the Bureau’s data, 70 percent of firearms recovered and traced in drug cartel crimes
in Mexico originate from the United States.41 Prior to the implementation of the southwest long
gun reporting rule, the lack of any long gun requirement was identified by the federal
government as a “key challenge [in] combat[ing] illicit sales of firearms in the United States.”42
And the reach of Mexican cartels extends far beyond the four border states currently subject to
the long gun multiple sales reporting requirement. Mexican drug trafficking organizations
control most of the American drug market, and they have distribution networks in at least 230
American cities in over 40 states across the country, from the Pacific Northwest to New England
to the Deep South.43 While the majority of the Mexican crime guns traced to dealers in the
United States from 2004 to 2008 came from Arizona, California, and Texas, roughly one-third of
those guns came from the rest of the country.44
b. The Bureau Faces Other Roadblocks to Effective Crime Prevention, Making
a Long Gun Reporting Requirement Even More Imperative.
The Bureau is hamstrung by obstacles that make it difficult to stop traffickers and prevent crime,
making it even more essential that law enforcement be empowered with real-time information
about multiple long gun sales. In particular, one rider attached to the federal budget obstructs the
Bureau’s enforcement efforts.
The “inventory rider” prevents the Bureau from requiring licensed dealers to account for
trafficked guns by maintaining an annual inventory. Since 2004, this rider has prohibited the
Bureau from requiring dealers to account for their inventory, even though dealers are required to
maintain records by federal law and would not be burdened by inventory requirements. Gun
dealers are obligated to report all lost and stolen guns to the Bureau, and guns reported as lost or
stolen frequently end up at crime scenes, indicating that theft is a common channel for diverting
guns into criminal hands. And a recent OIG report shows that tens of thousands of guns go
missing from dealer inventory each year—many of them falling into the hands of traffickers. 45
But because they are not required to keep an inventory, corrupt dealers can sell guns to
traffickers and other prohibited purchasers and then later claim that the guns are lost or stolen if
they show up in a crime or come up missing during a Bureau inspection. And the Bureau cannot
address this problem simply with routine dealer inspection, as it does not have the resources to
inspect gun dealers regularly. Indeed, the Bureau inspects less than 58 percent of dealers in any
five-year period.46

41 Dianne Feinstein, Charles Schumer and Sheldon Whitehouse, Halting U.S. Firearms Trafficking to Mexico,
UNITED STATES SENATE CAUCUS ON INT’L NARCOTICS CONTROL (June 2011), available at http://1.usa.gov/xcJjch.
42 Firearms Trafficking, supra note 6, at 24.
43 Firearms Trafficking, supra note 6, at 1-2, Fig. 2 at 9.
44 Id. at 19.
45 U.S. DEPARTMENT OF JUSTICE, OFFICE OF THE INSPECTOR GENERAL, EVALUATION AND INSPECTIONS DIVISION,
Review of ATF’s Federal Firearms Licensee Inspection Program (April 2013), at 2, available at
http://1.usa.gov/1jukI2g [hereinafter Federal Firearms Licensee Inspection Program].
46 Id. at 13.
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Congress has hamstrung law enforcement with this rider, blocking the Bureau from collecting
critical information that would expose corrupt dealers and stop crime in its tracks. In the absence
of that comprehensive information, extending the long gun multiple sales reporting requirement
to dealers in every state would give the Bureau real-time information about sales that are
uniquely indicative of trafficking.
c. The Bureau Has Authority to Extend the Requirement to All 50 States and
Such an Extension Would Not Burden Dealers.
As discussed above, every federal court that has considered the Bureau’s authority to require
multiple sales reporting of certain long guns in the four border states has concluded that the
Demand Letter 3 program is well within the powers granted to the Bureau by federal law. Courts
have recognized that the long gun reporting under Demand Letter 3 constitutes “record
information” collection under 18 U.S.C. § 923(g)(5)(A) and that therefore the Bureau may issue
a letter requiring collection of such information. As the Ninth Circuit observed, “[w]hile
Congress has long sought to prohibit the Bureau from establishing a national firearms registry,
the Bureau’s actions here do not come close to realizing this forbidden goal. Rather, the demand
letter at issue seeks a limited amount of information from [federal firearms licensee] dealers in
order to help remedy the problem posed by tracing secondhand firearms.”47
Likewise, expansion of the reporting requirement to all 50 states does not create a national
system of registration of firearms, prohibited by 18 U.S.C. § 926(a), as the Demand Letter 3
program is limited by its very nature to only certain types of transactions, covering a relatively
small percentage of total firearms sales by licensed dealers in the United States.48 Extending the
program to all 50 states would continue to be within the broad grant of demand letter authority in
18 U.S.C. § 923(g)(5) and would not conflict with other limitations placed upon the Bureau by
federal statute.
Moreover, licensed dealers in the 50 states will not be burdened by this reporting requirement.
Dealers have been required to file a similar form for multiple sales of handguns for almost 40
years and are accustomed to this reporting. Dealers are also already required by federal law to
keep detailed records for all acquisitions and dispositions, and any additional time required for
reporting multiple long gun sales would be minimal. Indeed, the current proposed information
collection estimates that the multiple sales form takes only 12 minutes to complete—and
estimates that only a total of 3,615 hours annually will be spent on the requirement, which affects
over 2,500 dealers in the border states.
Regardless of whether the Bureau does extend the long gun reporting requirement to 50 states, it
should regularly publish data on the impact of existing multiple sales requirements—including
how many investigations were initiated or aided based on these reports, how many guns were
seized, how many prosecutions were recommended, and how many indictments and convictions

47 J.G. Sales v. Truscott, 473 F.3d 1043, 1049 (9th Cir. (2007); see also e.g., Nat’l Shooting Sports Found., Inc. v.
Jones, 716 F.3d 200, 207-10 (D.C. Cir. 2013).
48 Id. at 212-14.
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were obtained. This vital information would further the record in this area and help to
demonstrate the critical importance of this tool.
5. Recommendation.
For the reasons outlined above, Everytown supports the Bureau’s extension of the multiple sales
reporting requirement for certain rifles in Arizona, California, New Mexico, and Texas. In
addition, Everytown encourages the Bureau to extend this reporting requirement to dealers in all
50 states.
Everytown appreciates the Bureau’s efforts in proposing the extension of the current information
collection and thanks the Bureau for the opportunity to offer this comment.
Respectfully submitted,
/s/
Megan Lewis
Deputy Executive Director
Everytown for Gun Safety