Tom Odom at the Prince Law Blog has prepared an analysis of procedural problems with the proposed rule change:
http://blog.princelaw.com/2013/08/30...raft-proposal/
This proposed rule change has not been published in the Federal Register yet so it appears the comment period has not yet started.
Additionally, the Prince Law Blog has prepared sample letters to send to ATF for FFLs (
http://princelaw.files.wordpress.com...-1-letter.docx) and for individuals who were denied a CLEO sign off (
http://princelaw.files.wordpress.com...eo-letter.docx)
Please do not just cut and paste these letters; but instead use them as a rough template to form your own personalized letters including specific relevant details. Remember ALl information will be public record so you may need to exercise INFOSEC during submission.