SAF Advises Strategy as ATF Deadline Looms for Comment on Stabilizer Braces

SIG SAUER Pistol Stabilizing Brace
ATF is proposing a rule change that will affect owners of pistol stabilizing braces like this one from SIG SAUER. Deadline for comment is Sept. 8.

U.S.A.-( With the Sept. 8 deadline looming to submit comments to the Bureau of Alcohol, Tobacco, Firearms and Explosives on the proposed rule change regarding the classification of pistol stabilizer braces, the Second Amendment Foundation has launched a video tutorial and is providing tips to gun owners about how to get their comments in on time.

SAF has already submitted its 14-page detailed perspective on the proposal, and it pulls no punches. Right up front, the gun rights organization tells the ATF Office of Regulatory Affairs, “ATF does not have the authority to impose NFA control on stabilizing braces and its proposed rule will threaten millions of citizens with prison, harsh fines, forfeiture of firearms, and the loss of the right to own or possess firearms should they fail to comply with ATF’s policy change. The NFA was not amended for these changes. No new laws were passed. Instead, ATF decided to change the scope of the NFA on its own, imposing significant burdens on core constitutional rights of over a million law abiding citizens.”

According to SAF founder and Executive Vice President Alan Gottlieb, “ATF wants to reclassify millions of stabilizing brace-equipped pistols by making them subject to the National Firearms Act (NFA). If that happens, current owners of such pistols would need to register their guns and pay a $200 tax on each one, or turn it in to the ATF, or take one of several other undesirable options.”

SAF’s Alan Gottlieb

For Gottlieb, it’s a non-starter.

“Under the proposed rule,” he says in his letter to ATF,  “affected persons (i.e., persons who possess stabilizing brace equipped pistols caught by ATF’s expanded NFA controls) would need to take one of the following actions before the effective date of a final rule:

  1. Permanently remove or alter the stabilizing brace such that it cannot be reattached, converting the firearm back to its original pistol configuration;
  2. Remove the short barrel and attach a 16-inch or longer barrel to the pistol;
  3. Destroy the firearm;
  4. Turn the firearm into a local ATF office; or
  5. Complete and submit an Application to Make and Register a Firearm, ATF Form 1 and pay the $200 tax.”

According to Gottlieb’s letter, under the proposed rule, ATF “now seeks to amend the definition of ‘rifle’ in definitional sections of the regulations implementing the Gun Control Act (of 1968) and NFA …to expand NFA control to cover ‘any weapon with a rifled barrel equipped with an accessory or component purported to assist the shooter (to) stabilize the weapon while shooting with none hand, commonly referred to as a ‘stabilizing brace’ that has objective design features and characteristics that facilitate shoulder fire, as indicated on a new proposed ATF Worksheet 4999.”

It sets up a system of “point values” ranging from 0 to 4 points “based upon the degree of the indicator,” according to Gottlieb’s letter to ATF. This is the point system:

  • 1 point: Minor Indicator (the weapon could be fired from the shoulder)
  • 2 points: Moderate Indicator (the weapon may be designed and intended to be fired from the shoulder)
  • 3 points: Strong Indicator (the weapon is likely designed and intended to be fired from the shoulder)
  • 4 points: Decisive Indicator (the weapon is designed and intended to be fired from the shoulder)

The problem with this, according to Gottlieb, is that a firearm accumulating 4 or more points in either section will be classified as an NFA short barreled rifle (SBR), while a pistol that accumulates less than 4 points in Section II (Accessory characteristics) and less than 4 points in Section III (Configuration of Weapon) “will generally be determined not to be designed to be fired from the shoulder.”

“However,” he states, “ATF reserves the discretion to impose NFA control on any pistol not caught by the scoring scheme where ‘there is evidence that the manufacturer or maker expressly intended to design the weapon to be fired from the shoulder.’ In other words, as stated in the proposed ATF Worksheet 4999, the scheme would allow ATF to impose NFA control over pistols that do not exceed the stated threshold.”

The deadline is less than two weeks away. Gun owners may submit comments online here.

“Time is running out and we want to provide millions of targeted gun owners the means to weigh in on this alarming proposal,” Gottlieb said.

Written comments may be sent to:

Denise Brown, Mail Stop 6N– 518

Office of Regulatory Affairs

Enforcement Programs and Services

Bureau of Alcohol, Tobacco, Firearms, and Explosives

99 New York Ave. NE

Washington, DC 20226

ATTN: ATF 2021R-08

Gottlieb concludes his letter to ATF by stating, “ATF’s authority under the NFA is limited. It must focus on clear rules that conform to the law and that do not violate constitutional rights. 45 ATF must not, as it proposes, open the Pandora’s box of unjustified burdens and legal infirmities presented by its proposed rule. Because of this, and based on the above, SAF urges ATF to reconsider its position.”

For more information on SAF, visit their website.

About Dave Workman

Dave Workman is a senior editor at and Liberty Park Press, author of multiple books on the Right to Keep & Bear Arms, and formerly an NRA-certified firearms instructor.

Dave Workman

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How is it that OUR comments get monitored but THIS stuff doesn’t?


All part of e AI algorithms on the IoT “webb” digital domain they control.
In our faces indeed.


Now I know how a lot of people in pre war Germany felt!


“In other words, as stated in the proposed ATF Worksheet 4999, the scheme would allow ATF to impose NFA control over pistols that do not exceed the stated threshold.”
The old “we’ll know it when we see it……just trust us” rule.


“….impose NFA control on stabilizing braces and its proposed rule will threaten millions of citizens with prison, harsh fines, forfeiture of firearms, and the loss of the right to own or possess firearms should they fail to comply with ATF’s policy change.”
UH….quit hammering what ATF sees as positive features. Address negatives….


I will tell them the truth. I will comply and put a 16″ upper on my braced pistol lower. I will then build a pistol compliant lower (hopefully based on an 80%) for my short barrel upper. Their goal is to improve public safety by reducing number of firearms. In this case one low power – accurate pistol will turn into a higher power (due to longer barrel) rifle plus a (scary ghost gun) pistol which will be less controllable, thus less accurate and more dangerous. I will not be handing them more cash to pursue their vainglorious agenda. I… Read more »


That which you allow is what will continue. Continually redefining what meaning of “IS” is with more bureaucratic onerous legislation serves exactly who’s agenda ? Only the ruling overlords of control.

It’s like having the DOJ/FBI/GOI investigate itself. It’s futile b/c it never corrects or admits it’s corruption or injustices.

When Rumsfeld announced in 01’ & told the American people right before the Black Swan 9/11 event over 2 Trillion USD just disappeared/vanished we all know then.

It’s a tyrannical overreaching sanguine corpus that’s need to collapse & restored to the American people.

Last edited 1 year ago by Tank

Term limits. Hold elected politicians accountable. Allowing a corrupt government to investigate itself is like allowing the Mafia to regulate morality.

“We call it riding the Gravy Train.”
Pink Floyd


I just submitted my comments about opposing the regulations of a brace attached to my firearms, now I just hope they don’t know down my door in the middle of the night and shoot me

Roland T. Gunner

Just die a slow and painful death already.


Yes 4th Reich is doing exactly that. However the Technocracy emerging is another scary reality to face with the continued ignorance by so many.


very well written document, great job. the capricious amending of regulations asserting control over the citizens is what bureaucracies do. congress has abdicated its authority to the administrative state in order to allow them more time for re-election. there should be term limits for all elected officials, and number of times elected. government officials/employees were never expected to spend their whole lives on the public payroll. likely, this will have to go through litigation to resolve, and hopefully, scotus will decide based upon the Constitution and Bill of Rights. not always the case. the government does not seek to help… Read more »


Yep 100% true.


Dave Workman, why not take responsibility/apologize for saving LaPierre & Co in ’97, enabling them to loot the NRA?

Last edited 1 year ago by Russn8r

Today’s NRA Looting News

Dave, say sorry for making this possible by saving LaPew in ’97.


~“We tried to fire LaPew in ’97. Turncoat Workman saved him.”

Will he ever say sorry for helping LaPewCo loot the NRA?

<Crickets Chirping> Chirp…Chirp…Chirp…

Last edited 1 year ago by Russn8r

~“We tried to fire LaPew in ’97. Workman saved him.”

Still waiting for Dave to say sorry for helping LaPewCo loot the NRA.



WHY are people down-voting this?


Why are Harry & David’s sock puppets downvoting it? LoL. I don’t live for upvotes or cry over downvotes.

Per NRAinDanger, Marion Hammer alerted her toady posse to skew a Guns & Ammo poll. Early on they had it 75% “completely trust NRA”. Check it now: