Executive Action to Strengthen Background Checks by Addressing High-Volume Gun Sellers

8202019 Executive Action to Strengthen Background Checks by Addressing High-Volume Gun Sellers

httpslidepdfcomreaderfullexecutive-action-to-strengthen-background-checks-by-addressing-high-volume 19

1 Center for American Progress | Executive Action to Strengthen Background Checks by Addressing High-Volume Gun Sellers

Executive Action to Strengthen

Background Checks by AddressingHigh-Volume Gun SellersBy Chelsea Parsons and Arkadi Gerney October 15 2015

In recen years proponens o sronger gun laws have coalesced around one key legisla-

ive proposal close he loopholes in he law ha allow guns o be sold wihou a back-

ground check Tis gap in he law is a primary way ha dangerous individuals legally

prohibied rom gun ownership991252such as hose conviced o violen elonies domesicabusers and ugiives991252are able o acquire guns1 Such effors have ocused primarily on

legislaion a boh he ederal and sae level ha would amend exising law o require

all sellers o guns no jus licensed gun dealers o conduc a background check beore

compleing a sale While hese effors have salled in Congress a number o saes have

made progress o enac universal background checks including he 2013 passage o such

a law in Colorado2 a successul ballo iniiaive in Washingon sae in November 20143

and mos recenly he enacmen o a new Oregon sae law in May 2015 4

However i is also possible o address aspecs o his loophole via execuive acion a

he ederal level Federal law requires individuals who are deemed o be ldquoengaged in he businessrdquo o dealing in firearms o obain a ederal firearms license or FFL rom he

Bureau o Alcohol obacco Firearms and Explosives or AF5 Becoming a licensed gun

dealer has wo primary consequences Te licensee is subjec o oversigh and regula-

ion by AF and is required o conduc background checks or all gun sales Ensuring

ha all individuals who are engaged in he business o selling guns are in ac licensed

has significan implicaions or he number o ransacions ha are covered by he exis-

ing sauory background check requiremen

Unorunaely he exising sauory and regulaory language regarding wha exacly i

means o be ldquoengaged in he businessrdquo is vague and ambiguous and provides insufficien

guidance o individuals AF and ederal prosecuors regarding who is required o

obain a ederal firearms license because o he volume and characer o heir gun sales

and who is violaing he law or ailing o do so Tis weakness in he curren regulaory

ramework allows unscrupulous individuals o exploi his ambiguiy and sell guns a a

high volume wihou oversigh rom AF and wihou conducing background checks




In recen weeks he issue o his weakness in he curren regulaory definiion o wha

i means o be engaged in he business o dealing in firearms or purposes o deermin-

ing who is required o become a licensed gun dealer has received naional atenion and

he Obama adminisraion has indicaed ha i is considering opions or amending he

regulaion6 In his issue brie he Cener or American Progress offers opions or how

he regulaion could be amended o provide beter guidance regarding when an indi-

vidual is engaged in he ype and volume o reail gun sales ha warran AF oversighhrough a ederal firearms license CAP also examines he ramework many saes use

o deermine which reail sellers are engaged in business aciviy ha warrans collec-

ion o sae sales ax as a useul analogy or how he aoremenioned engaged-in-he-

business regulaion could be improved CAP proposes a nuanced approach ha would

ake ino accoun a number o acors in deermining wheher an individual is engaged

in he business o dealing in firearms ha includes no only he number o guns sold bu

also oher aspecs o he business such as requency o sales oal proceeds and oher

indicaors o he commercial naure o he sales aciviy Finally CAP concludes ha he

Obama adminisraion can and should rewrie he ederal regulaion ha defines which

gun sellers are required o conduc background checks991252and ha doing so would repre-sen a meaningul bu modes sep oward he goal o ensuring ha all gun sales involve

a background check

Weaknesses in the current regulation

Federal law requires ha any person who is ldquoengage[d] in he businessrdquo o ldquodealing in

firearmsrdquo obain a ederal firearms license rom AF and become a licensed gun dealer7

Such licensed dealers are he only individuals mandaed by ederal law o conduc back-

ground checks prior o compleing any gun sale Te saue goes on o define he ermas ollows

A person who devoes ime atenion and labor o dealing in firearms as a regular

course of rade or business wih he principal objecive of livelihood and profi hrough

he repeiive purchase and resale of firearms bu such erm shall no include a person

who makes occasional sales exchanges or purchases of firearms for he enhancemen

of a personal collecion or for a hobby or who sells all or par of his personal collec-

ion of firearms8

Te curren AF adminisraive regulaion ha provides addiional definiion and

clarificaion regarding a number o sauory provisions relaed o AF ound in secion

47811 o ile 27 o he Code o Federal Regulaions offers an idenical definiion o he

erm and does no provide any urher guidance abou how o assess wha consiues

ldquooccasional salesrdquo or how o deermine wheher a personrsquos reail aciviy is underaken

ldquowih he principal objecive o livelihood and profirdquo9 Tis is precisely he purpose o




enacing a body o adminisraive regulaions relaing o ederal legislaion o provide

addiional adminisraive guidance as o how he regulaory agency should inerpre and

apply cerain erms and conceps

Tis vagueness in he curren regulaory definiion has provided he opporuniy or

individuals o ake advanage o he ambiguiy and sell guns a a high volume wihou

becoming licensed and hereore wihou conducing background checks I also makesi difficul or law enorcemen o successully charge someone wih violaing he law by

selling guns wihou a license Former AF agen John Risenhoover in a recen iner-

view explained he challenge o meeing he high burden o proo creaed by he curren

vague regulaory definiion o engaged in he business ldquoYou know how you can bea

any o hese cases Shu up I you donrsquo say anyhing irsquos really hard o proverdquo 10 He also

relayed ha gun sellers are well aware o his challenge or law enorcemen and ofen

knowingly exploi i or profi ldquoI you go o gun shows in he deep Souh or Arizona

here will be people who have boohs where hey go buy new guns rom an FFL and hen

sell hem a a markup under a sign saying lsquono paperwork necessaryrsquordquo said Risenhoover11

Even wih hese challenges here have been some successul recen prosecuions o

individuals who illegally sold guns wihou a license ha provide a limied glimpse ino

he kind o unlicensed gun sales ha pose he bigges concern or law enorcemen12

In July 2015 an individual in Orlando Florida was conviced o selling guns wihou a

license afer he sold 113 guns over a 14-monh period or around $63000 including a

leas one sale o a prohibied purchaser13 In June 2015 an individual in Camden New

Jersey was conviced o selling guns wihou a license afer he admited o selling a

leas 200 handguns over a nine-monh period many o which were sold o an admited

drug dealer who hen resold many o hose guns o oher drug dealers14 In May 2013 a

woman in Manassas Virginia was conviced or violaing his law afer she purchased 31handguns a guns shows across hree consecuive weekends wih he inen o reselling

hem A number o hese guns were laer used in drug-rafficking crimes in Maryland15

State sales tax collection laws and regulations An instructive analogy

As policymakers consider opions or amending he regulaion o provide beter

guidance as o wha i means o be engaged in he business one useul se o laws ha

provides a model is sae laws governing who is required o collec sae sales ax Nearly

every sae imposes a sales ax on goods sold wihin he sae16 In many saes cerain

individuals and eniies are exemp rom he sales ax collecion requiremen i hey

engage in low-volume or inrequen sales ofen described as ldquooccasionalrdquo or ldquocasualrdquo

sales Many o hese sae laws ake a nuanced approach o deermining wha consiues

an occasional or casual sale ha considers no only he raw number o producs sold

bu also oher acors ha assess he overall naure o he business such as requency o

sales aciviy characer o producs being sold and amoun o money earned hrough

he sales ransacions By and large hese sae laws and regulaions defining wha kinds




o sellers should collec axes are more houghul precise and enorceable han he

curren vague ederal regulaion ha defines ldquoengaged in he businessrdquo as relaing o gun

sales Examinaion o some o hese sae sauory and regulaory schemes or deermin-

ing which vendors are obligaed o collec sales ax provides useul guidance or redraf-

ing he engaged-in-he-business gun regulaion

Missouri

In Missouri he ollowing acors are o be considered in deermining wheher an

individual is engaged in business and hereore required o collec sales ax wheher he

individual adverises or oherwise holds him or hersel ou as being a reailer requency

and duraion o sales aciviy and he naure o he marke or he good or service being

sold Missouri law and regulaion also provide ha regardless o he above acors any

individuals who earn more han $3000 in a calendar year hrough heir sales aciviy

will no be considered o be engaging in occasional or isolaed sales17

Nebraska

Nebraska exemps rom he sales ax collecion requiremen individuals who are only

engaged in occasional sales Sales aciviy only qualifies as an occasional sale i al l o he

ollowing condiions are me Te sales ake place a he personrsquos residence or via an

online aucion sie sales occur no more han hree days during he calendar year nei-

her he individual nor any members o he individualrsquos household operaes a business

in which similar producs are sold he propery being sold was originally purchased or

he individualrsquos personal use and he propery being sold is no subjec o any oher lawha would require ha he sale no be considered occasional Nebraska also provides

ha any sale ha is aided by an agen or aucioneer any sale in which he seller did no

pay sales ax when he or she firs purchased he iem and any sale o propery ha was

originally purchased or he purpose o resale do no quali y as occasional sales18 I

Nebraskarsquos rules were applied o guns mos o he aciviy o unlicensed sellers operaing

ables a gun shows would clearly be beyond he occasional-sale excepion Such unli-

censed gun show sellers commonly sell new-in-he-box guns ren space a he show o

sell he guns operae a more han hree shows a year and operae ouside heir homes19

Texas

exas also provides an occasional-sales excepion o is sales ax collecion requiremen

Sae law and regulaion provide ha here are wo caegories o qualiying sales Firs

an individual who engages in only one or wo sales a reail during a 12-monh period

and does no hold him or hersel ou o be engaged in he business o selling such iems

a reail qualifies or he occasional-sales excepion Second he sales are considered o




be occasional sales i he ollowing acors are me Te propery was originally pur-

chased by he individual or a amily member or personal use he individual does no

have a permi o be a seller or reailer as required by sae law he individual does no

use a broker or aucioneer o aciliae he sale and he oal proceeds rom he sale in a

calendar year do no exceed $300020

West Virginia

Individuals who engage in wha are deemed ldquoisolaed ransacionsrdquo are no required o

collec sales ax in Wes Virginia Sales qualiy as isolaed ransacions i he seller is no

in he business o regularly selling he ype o produc being sold and he seller does no

engage in more han our isolaed ransacions in a 12-monh period21

Florida

Florida law exemps occasional sales o goods rom sales ax collecion Te ollowing

condiions mus be me o qualiy or his exempion Te seller paid sales ax when he

or she originally bough he iem he individual does no engage in sales aciviy more

han wice during a 12-monh period he propery was no originally purchased or he

purpose o resale he sales do no ake place on commercial premises or anoher loca-

ion where hey are compeing wih oher reailers who are required o collec sales ax

and he sale is no made hrough an aucioneer or oher agen who is required o collec

sales ax2

Review of these state laws

demonstrates

ha i is commonplace or laws and regula-ions o esablish clear guidelines abou wha ype o reail sales conduc should be con-

sidered casual occasional or par o a hobby and wha ype o sales are clearly par o an

esablished business underaken or he primary purpose o profi An updaed regula-

ion defining engaged in he business in he gun sales conex could ollow he approach

aken in many o hese sae laws and regulaions

Options for strengthening the regulatory definition of engaged in

the business

A revised regulaion defining wha i means o be engaged in he business o dealing

in firearms or he purpose o deermining who is required o obain a ederal firearms

license and by exension conduc background checks or all gun sales should ake

a nuanced approach A revised regulaion should consider a ew differen acors o

accuraely gauge wheher individuals selling guns a reail are in ac engaging in sales

o such volume and characer ha hey should be reaed as gun dealers under he law




While a sric numerical hreshold based on number o sales would offer a brigh-line

rule ha would provide clear guidance such an approach in isolaion would ail o ake

ino accoun all o he aspecs o reail sales o firearms ha should be par o he deer-

minaion as o wheher an individual should be required o become a licensed dealer A

numerical hreshold should be a componen o a revised regulaion as i is in many sae

sales ax laws and would provide a useul signal o he marke o gun sellers However

jus as many saes consider a number o acors in deermining wheher a seller o goodsshould be required o collec sales ax a revised regulaion relaing o gun sellers should

consider oher acors in addiion o he number o guns sold Te ollowing acors

should be considered in a revised regulaory scheme and he presence o some o hese

acors should creae a rebutable presumpion ha he individual is engaged in he busi-

ness o dealing in firearms

Quantity of sales

One acor o consider in deermining wheher an individual is engaged in he businesso dealing in firearms is he volume o he business during a 12-monh period Tere are

a ew opions or quaniying business volume

bull Number o guns offered or sale

bull Number o guns sold

bull Amoun o money involved in sales ransacions

Character of sales activity

Anoher elemen o a comprehensive approach o assessing wheher someone is

engaged in he business o dealing in firearms is consideraion o oher aspecs o he

gun sales ha indicae he commercial naure o he sales and a subsanial business in

guns Such acors may include

bull Rening ables a gun shows or flea markes

bull Operaing a virual sore online

bull Frequency o sales aciviy

bull Adverising he sale o guns

bull Acceping credi card paymens




bull Formal record keeping

bull Paying employees

bull Selling new and unopened guns

bull Selling muliple guns wih he same make and model

In addiion o clariying he ypes o sales ha should be considered sufficienly commer-

cial aciviy o qualiy as engaging in he business a revised regulaion should also pro-

vide clear guidance as o wha ypes o sales should no be considered when deermining

wheher an individual needs o obain an FFL Tese exemp sales should include

bull Any sale made o a licensed dealer or a privae sale or which a background check was

conduced hrough a dealer

bull Liquidaing a privae collecion wih some limiaions

bull Selling guns as par o setling an esae

A new regulaion should also clariy ha so-called fire sales991252meaning sales o all guns

in invenory when a licensed dealer has his or her license revoked991252consiue engaging

in he business and require a ederal firearms license Under curren pracice ollowing a

2006 opinion by he US Deparmen o Jusice dealers whose licenses are revoked are

permited o ranser he invenory rom heir sore o heir personal collecion and con-

inue o sell hose guns as privae sellers regardless o he quaniy o guns sold in his

manner23

Pu simply he Jusice Deparmenrsquos 2006 opinion leter makes no sense andis inconsisen wih he leter and inen o he exising saue Tis reading o he law

is a odds wih he plain language o he saue and creaes a significan risk o public

saey by allowing proven bad acors o coninue selling guns a a high volume wihou

being required o keep any paperwork or conduc background checks A revised regula-

ion should make i clear ha dealers who lose heir licenses should no be permited o

sell off heir invenory as privae sellers hrough fire sales bu raher should be required

o dispose o hese firearms by selling hem o oher licensed dealers24

Conclusion

In his passionae and angry remarks ollowing he Ocober 1 2015 shooing a Umpqua

Communiy College in Roseburg Oregon991252he naionrsquos 45h school shooing his

year991252Presiden Barack Obama made i clear ha he is no willing o wai or Congress

o ake acion o address he loopholes in he naionrsquos curren gun laws which allow

people who pose an increased risk o public saey o have easy access o guns25 Indeed




he presiden has been a srong leader on he gun issue since he December 2012 shoo-

ing a Sandy Hook Elemenary School when he ook a number o execuive acions o

address various aspecs o gun violence in he Unied Saes beginning wih 23 acions

announced in January 201326 Te presiden should add o his legacy o leadership

by using his exising execuive auhoriy o amend he regulaory definiion o wha

i means o be engaged in he business o dealing in guns o provide much-needed

guidance o individuals and law enorcemen abou wha ype o sales aciviy requireslicensure by AF Doing so would be a srong sep oward reducing he number o guns

ha change hands every year wihou a background check991252guns ha oo ofen end up

in he wrong hands wih devasaing resuls

Chelsea Parsons is Vice Presiden of Guns and Crime Policy a he Cener for American

Progress Arkadi Gerney is a Senior Vice Presiden a he Cener




Endnotes

1 Center for American Progress ldquoBackground Checks for AllGun Salesrdquo (2015) available at httpscdnamericanprogressorgwp-contentuploads201502BackgroundChecks-factsheet3pdf

2 CNN ldquoColorado governor signs gun control mea-suresrdquo March 20 2013 availabl e at httpwwwcnncom20130320uscolorado-gun-control

3 Michele Richinick ldquoGun control wins in Washington StaterdquoMSNBC November 13 2014 available at httpwwwmsn-bccommsnbcgun-control-wins-washington-state54914

4 Reuters ldquoOregon governor signs gun background checksbillrdquo May 12 2015 available at httpwwwreuterscomarticle20150512us-usa-oregon-guncontrol-idUSKBN-0NX0J920150512

5 18 USC sect 922(a)(1)(A)

6 Juliet Eilperin ldquoObama weighs expanding backgroundchecks through executive authorityrdquoThe Washington Post October 8 2015 available at httpswwwwashingtonpostcompoliticsobama-weighs-expanding-background-checks-through-executive-authority201510086bd45e56-6b63-11e5-9bfe-e59f5e244f92_storyhtml

7 18 USC sect 922(a)(1)(A)

8 18 USC sect 921(21)(C)

9 27 CFR sect 48711

10 Alex Yablon ldquo5 Cases That Show How Unlicensed DealersHave Sold Guns By the Hundredsrdquo The Trace October 72015 available at httpwwwthetraceorg201510hillary-clinton-background-check-plan

11 Ibid

12 For additional case examples see Yablon ldquo5 Cases ThatShow How Unlicensed Dealers Have Sold Guns By theHundredsrdquo

13 US Department of Justice ldquoKissimmee Man Pleads Guilty toDealing in Firearms Without a Licenserdquo Press release July 172015 available at httpswwwatfgovnewsprkissimmee-man-pleads-guilty-dealing-firearms-without-license

14 US Department of Justice ldquoIllegal Firearms Dealer AdmitsSelling More Than 200 Guns to Drug Dealers and OtherCriminals in the Camden Areardquo Press release June 23 2015available at httpswwwatfgovnewsprillegal-firearms-dealer-admits-selling-more-200-guns-drug-dealers-and-other-criminals-camden

15 US Department of Justice ldquoManassas Woman Sentenced To 18 Months For Illegally Buying And Selling More Than 31Handguns In 15 Daysrdquo Press release May 3 2013 availableat httpwwwjusticegovusao-edvaprmanassas-woman-sentenced-18-months-illegally-buying-and-selling-more-31-handguns-15

16 According to the Tax Foundation all but five states haveimposed a statewide sales tax See Scott Drenkard andJared Walczak ldquoState and Local Sales Tax Rates in 2015rdquo TaxFoundation April 8 2015 available at httptaxfoundationorgarticlestate-and-local-sales-tax-rates-2015

17 Mo Rev Stat sect 1440101(2) 12 CSR 10-103200

18 Neb Rev Stat sect 77-270124 Reg sect 1-02201

19 For more examples regarding conduct at gun shows seeCity of New York ldquoGun Show Undercover Report on Ill egalSales at Gun Showsrdquo (2009) available at httpwwwnycgovhtmlompdf2009pr442-09_reportpdf

20 Tex Tax Code Ann sect 151304 34 TAC 3316

21 W Va Code sect 11-15-9(a)(7) Reg sect 110-1592 110-15239

22 Fla Stat sect21202(2) Rule 12A-1037

23 Mayors Against Illegal Guns ldquoA Blueprint for Federal Actionon Illegal Gunsrdquo (2009) p 8 available at httpeverytownre-searchorgreportsa-blueprint-for-federal-action-on-illegal-guns

24 For an in-depth discussion of the issue of fire sales see Arka-di Gerney and Chelsea Parsons ldquoRecommendations for Ex-ecutive Action to Combat I llegal Gun Trafficking and ReduceGun Crimerdquo (Washington Center for American Progress2013) pp 9ndash10 available at httpscdnamericanprogressorgwp-contentuploads201306ExecActionGuns-4pdf

25 The White House ldquoStatement by the President on the Shoot-ings at Umpqua Community College Roseburg OregonrdquoPress release October 1 2015 available at httpswwwwhitehousegovthe-press-office20151001statement-president-shootings-umpqua-community-college-rose-burg-oregon

26 The White House ldquoNow is the Time Gun Violence Reduction

Executive Actionsrdquo (2013) available at httpswwwwhite-housegovsitesdefaultfilesdocswh_now_is_the_time_actionspdf




In recen weeks he issue o his weakness in he curren regulaory definiion o wha

i means o be engaged in he business o dealing in firearms or purposes o deermin-

ing who is required o become a licensed gun dealer has received naional atenion and

he Obama adminisraion has indicaed ha i is considering opions or amending he

regulaion6 In his issue brie he Cener or American Progress offers opions or how

he regulaion could be amended o provide beter guidance regarding when an indi-

vidual is engaged in he ype and volume o reail gun sales ha warran AF oversighhrough a ederal firearms license CAP also examines he ramework many saes use

o deermine which reail sellers are engaged in business aciviy ha warrans collec-

ion o sae sales ax as a useul analogy or how he aoremenioned engaged-in-he-

business regulaion could be improved CAP proposes a nuanced approach ha would

ake ino accoun a number o acors in deermining wheher an individual is engaged

in he business o dealing in firearms ha includes no only he number o guns sold bu

also oher aspecs o he business such as requency o sales oal proceeds and oher

indicaors o he commercial naure o he sales aciviy Finally CAP concludes ha he

Obama adminisraion can and should rewrie he ederal regulaion ha defines which

gun sellers are required o conduc background checks991252and ha doing so would repre-sen a meaningul bu modes sep oward he goal o ensuring ha all gun sales involve

a background check

Weaknesses in the current regulation

Federal law requires ha any person who is ldquoengage[d] in he businessrdquo o ldquodealing in

firearmsrdquo obain a ederal firearms license rom AF and become a licensed gun dealer7

Such licensed dealers are he only individuals mandaed by ederal law o conduc back-

ground checks prior o compleing any gun sale Te saue goes on o define he ermas ollows

A person who devoes ime atenion and labor o dealing in firearms as a regular

course of rade or business wih he principal objecive of livelihood and profi hrough

he repeiive purchase and resale of firearms bu such erm shall no include a person

who makes occasional sales exchanges or purchases of firearms for he enhancemen

of a personal collecion or for a hobby or who sells all or par of his personal collec-

ion of firearms8

Te curren AF adminisraive regulaion ha provides addiional definiion and

clarificaion regarding a number o sauory provisions relaed o AF ound in secion

47811 o ile 27 o he Code o Federal Regulaions offers an idenical definiion o he

erm and does no provide any urher guidance abou how o assess wha consiues

ldquooccasional salesrdquo or how o deermine wheher a personrsquos reail aciviy is underaken

ldquowih he principal objecive o livelihood and profirdquo9 Tis is precisely he purpose o

















































Missouri








Nebraska















Texas














West Virginia





Florida








sales ax2


demonstrates







the business





















Quantity of sales





































manner23








Conclusion























Endnotes





5 18 USC sect 922(a)(1)(A)


7 18 USC sect 922(a)(1)(A)

8 18 USC sect 921(21)(C)

9 27 CFR sect 48711


11 Ibid

































































Missouri








Nebraska















Texas














West Virginia





Florida








sales ax2


demonstrates







the business





















Quantity of sales





































manner23








Conclusion























Endnotes





5 18 USC sect 922(a)(1)(A)


7 18 USC sect 922(a)(1)(A)

8 18 USC sect 921(21)(C)

9 27 CFR sect 48711


11 Ibid

























Missouri








Nebraska















Texas














West Virginia





Florida








sales ax2


demonstrates







the business





















Quantity of sales





































manner23








Conclusion























Endnotes





5 18 USC sect 922(a)(1)(A)


7 18 USC sect 922(a)(1)(A)

8 18 USC sect 921(21)(C)

9 27 CFR sect 48711


11 Ibid

























West Virginia





Florida








sales ax2


demonstrates







the business





















Quantity of sales





































manner23








Conclusion























Endnotes





5 18 USC sect 922(a)(1)(A)


7 18 USC sect 922(a)(1)(A)

8 18 USC sect 921(21)(C)

9 27 CFR sect 48711


11 Ibid































Quantity of sales





































manner23








Conclusion























Endnotes





5 18 USC sect 922(a)(1)(A)


7 18 USC sect 922(a)(1)(A)

8 18 USC sect 921(21)(C)

9 27 CFR sect 48711


11 Ibid






































manner23








Conclusion























Endnotes





5 18 USC sect 922(a)(1)(A)


7 18 USC sect 922(a)(1)(A)

8 18 USC sect 921(21)(C)

9 27 CFR sect 48711


11 Ibid


































Endnotes





5 18 USC sect 922(a)(1)(A)


7 18 USC sect 922(a)(1)(A)

8 18 USC sect 921(21)(C)

9 27 CFR sect 48711


11 Ibid




















Endnotes





5 18 USC sect 922(a)(1)(A)


7 18 USC sect 922(a)(1)(A)

8 18 USC sect 921(21)(C)

9 27 CFR sect 48711


11 Ibid

















Documents

Executive Action to Strengthen Background Checks by Addressing High-Volume Gun Sellers