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Well, after about six months waiting for a written response to my letter, I got tired and sent ATF an email asking about it. The response I got was laughable. Over and over again they pointed to the definition of "identification" (which has nothing to do with what I asked) and made the simple statement "ATF does not consider the "brown card" government issued". I asked for their definition of what "government issued" is and the legal justification of their statement, and they simply pointed back to the definition of "identification".
For those interested, below is the back and forth email text. You have to go to the bottom and scroll up to read it chronologically.
For those interested, below is the back and forth email text. You have to go to the bottom and scroll up to read it chronologically.
From:
Sent: Monday, May 04, 2011 7:41 PM
To: FIPB Regulatory Email inquiries
Subject: RE: CA Brown Card
Respectfully, none of the information given justifies this statement in the original response:
"The CA "Brown Card" is not considered government issued, and therefore cannot be used for ATF purposes."
If there is any further legal justification for this statement you can outline, I would be appreciative, and would suggest/request a formal written ruling to quell the doubt which surrounds this issue.
________________________________________
Subject: RE: CA Brown Card
Date: Mon, 2 May 2011 20:15:00 -0400
From: FEB2@usdoj.govhttp://www.atf.gov/field.
Regards,
Firearms Industry Programs Branch, ATF
From:
Sent: Monday, May 02, 2011 6:32 PM
To: FIPB Regulatory Email inquiries
Subject: RE: CA Brown Card
Due to the response below, I would ask as a follow up for a definition of what BATFE legally "considers" a "government-issued" document.
________________________________________
Subject: RE: CA Brown Card
Date: Mon, 2 May 2011 15:34:25 -0400
From: FEB2@usdoj.govhttp://www.atf.gov/regulations-rulin...ng-2001-5.htmlhttp://www.atf.gov/publications/news...er-2010-06.pdfhttp://www.atf.gov/publications/news...er-1999-09.pdfhttp://www.atf.gov/regulations-rulin...ing-2010-6.pdfhttp://www.naag.org.
We trust this correspondence has been responsive to your inquiry. Should you have any further questions, please feel free to contact your local ATF Industry Operations Office. A list of ATF Office telephone numbers can be found at http://www.atf.gov/field.
Regards,
Firearms Industry Programs Branch, ATF
From:
Sent: Sunday, April 24, 2011 2:54 AM
To: Webmaster
Subject:
In December of 2010 I wrote a letter to the BATFE inquiring about the conflicting information about the use of the California change of address card (form DL 43) issued by the DMV as alternate documentation for line 20b of the Federal form 4473. I have not received a reply to date and am currently hoping to get a "status" check of my inquiry. Attached you will find a copy of the letter which was sent in early December 2010 (5 months ago). I would appreciate any information on this matter.
Sent: Monday, May 04, 2011 7:41 PM
To: FIPB Regulatory Email inquiries
Subject: RE: CA Brown Card
Respectfully, none of the information given justifies this statement in the original response:
"The CA "Brown Card" is not considered government issued, and therefore cannot be used for ATF purposes."
If there is any further legal justification for this statement you can outline, I would be appreciative, and would suggest/request a formal written ruling to quell the doubt which surrounds this issue.
________________________________________
Subject: RE: CA Brown Card
Date: Mon, 2 May 2011 20:15:00 -0400
From: FEB2@usdoj.govhttp://www.atf.gov/field.
Regards,
Firearms Industry Programs Branch, ATF
From:
Sent: Monday, May 02, 2011 6:32 PM
To: FIPB Regulatory Email inquiries
Subject: RE: CA Brown Card
Due to the response below, I would ask as a follow up for a definition of what BATFE legally "considers" a "government-issued" document.
________________________________________
Subject: RE: CA Brown Card
Date: Mon, 2 May 2011 15:34:25 -0400
From: FEB2@usdoj.govhttp://www.atf.gov/regulations-rulin...ng-2001-5.htmlhttp://www.atf.gov/publications/news...er-2010-06.pdfhttp://www.atf.gov/publications/news...er-1999-09.pdfhttp://www.atf.gov/regulations-rulin...ing-2010-6.pdfhttp://www.naag.org.
We trust this correspondence has been responsive to your inquiry. Should you have any further questions, please feel free to contact your local ATF Industry Operations Office. A list of ATF Office telephone numbers can be found at http://www.atf.gov/field.
Regards,
Firearms Industry Programs Branch, ATF
From:
Sent: Sunday, April 24, 2011 2:54 AM
To: Webmaster
Subject:
In December of 2010 I wrote a letter to the BATFE inquiring about the conflicting information about the use of the California change of address card (form DL 43) issued by the DMV as alternate documentation for line 20b of the Federal form 4473. I have not received a reply to date and am currently hoping to get a "status" check of my inquiry. Attached you will find a copy of the letter which was sent in early December 2010 (5 months ago). I would appreciate any information on this matter.
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