"provided that other factors, as listed in the rule, indicate that the
weapon is designed, made, and intended to be fired from the shoulder"
The new rule is open ended in it's interpretation of various statements and definitions. It clearly states they rewrote the definition of rifle. The new definition has no clear measurements that can be made, and clearly rely on some ones interpretation of what the six (i to vi listed above) factors are, none of which can be measured consistently by varying people in varying situations. Then to say if you have any questions about an specific firearm, you can just send the firearm to us to evaluate, presumably with in their 120 days?.
While the rule clearly shows some examples of what they consider sbr's, they failed to provide any clear examples of what could be considered to meet their rule.
The rule changed an existing definition of a term used in various long standing laws, is ambiguous at best and the only specific items in it are the lists/pictures of what they consider not to meet the rule. As plenty of lawyers may tell you, the intent doesn't really matter if it contradicts what the rule actually says. And imo, it is not ATF's role to change definitions commonly used in laws without going through congress.
Unless someone owns one of the specific examples listed/pictured in the rule, they can not even questimate if their current item meets the law.
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