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(t)(4)(A) contains the same registry trap that Kopel and the Heritage Foundation criticized in M-T, the primary difference being that far fewer records would be produced and held by FFLs to potentially be within the government's reach in the future.
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I saw that and had the same thought but one big difference is the language immediately after prohibiting any officer or agency of the United States from establishing a registry.
I also noticed a 5yr sunset on everything but the registry prohibitions.