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For now, this particular discussion is moot. The following is copied from a follow-up notice, dated Dec. 31, 2020, on the page for this docket item:
“Upon further consultation with the Department of Justice and the Office of the Deputy Attorney General, ATF is withdrawing, pending further Department of Justice review, the notice and request for comments entitled “Objective Factors for Classifying Weapons with `Stabilizing Braces’,” that was published on December 18, 2020. 85 FR 82516. As explained in the notice, the proposed guidance was not a regulation. The notice informed and invited comment from the industry and public on a proposed guidance prior to issuing a final guidance document.
The withdrawal of the guidance does not change any law, regulation, or other legally binding requirement.”
How’s that for a Christmas present?