The Bureau of Alcohol, Tobacco, Firearms and Explosives has distributed the following letter to all Federal Firearms Licensees. Dated 3/22/22, it some FRTs are "machine guns" and are therefore regulated and "are also subject to registration, transfer, taxation, and possession restrictions" under the National Firearms Act. I couldn't find the info on the their website but this is the text of the letter from George Lauder, Assistant Director, Enforcement Programs and Services of the BATFE:

___________

U.S. Department of Justice
Bureau of Alcohol, Tobacco, Firearms and Explosives
Office of Enforcement Programs and Services Office of Field Operations
Washington, DC 20226
www.atf.gov

March 22, 2022

OPEN LETTER TO ALL FEDERAL FIREARMS LICENSEES

The Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) recently examined devices commonly known as “forced reset triggers” (FRTs) and has determined that some of them are “firearms” and “machineguns” as defined in the National Firearms Act (NFA), and “machineguns” as defined in the Gun Control Act (GCA).

These particular FRTs are being marketed as replacement triggers for AR-type firearms. Unlike traditional triggers and binary triggers (sometimes referred to generally as “FRTs”), the subject FRTs do not require shooters to pull and then subsequently release the trigger to fire a second shot. Instead, these FRTs utilize the firing cycle to eliminate the need for the shooter to release the trigger before a second shot is fired. By contrast, some after-market triggers have similar components but also incorporate a disconnector or similar feature to ensure that the trigger must be released before a second shot may be fired and may not be machineguns.

Both the NFA and GCA regulate machineguns. “Machinegun” is defined under 26 U.S.C. § 5845(b) and 18 U.S.C. § 921(a)(23) as—

Any weapon which shoots, is designed to shoot, or can be readily restored to shoot,
automatically more than one shot, without manual reloading, by a single function of the
trigger. The term shall also include the frame or receiver of any such weapon, any part
designed and intended solely and exclusively, or combination of parts designed and
intended, for use in converting a weapon into a machinegun, and any combination of
parts from which a machinegun can be assembled if such parts are in the possession or
under the control of a person. (Emphasis added.)

ATF’s examination found that some FRT devices allow a firearm to automatically expel more than one shot with a single, continuous pull of the trigger. For this reason, ATF has concluded that FRTs that function in this way are a combination of parts designed and intended for use in converting a weapon into a machinegun, and hence, ATF has classified these devices as a “machinegun” as defined by the NFA and GCA.

Accordingly, ATF’s position is that any FRT that allows a firearm to automatically expel more than one shot with a single, continuous pull of the trigger is a “machinegun”, and is accordingly subject to the GCA prohibitions regarding the possession, transfer, and transport of machineguns under 18 U.S.C. §§ 922(o) and 922(a)(4). They are also subject to registration, transfer, taxation, and possession restrictions under the NFA. See 26 U.S.C. §§ 5841, 5861; 27 CFR 479.101.

Under 26 U.S.C. § 5871, any person who violates or fails to comply with the provisions of the NFA may be fined up to $10,000 per violation and is subject to imprisonment for a term of up to ten years. Further, pursuant to 26 U.S.C. § 5872, any machinegun possessed or transferred in violation of the NFA is subject to seizure and forfeiture. Under 18 U.S.C. § 924(a)(2), any person who violates § 922(o) may be sent to prison for up to 10 years and fined up to $250,000 per person or $500,000 per organization.

Based on ATF’s determination that the FRTs that function as described above are “machineguns” under the NFA and GCA, ATF intends to take appropriate remedial action with respect to sellers and possessors of these devices. Current possessors of these devices are encouraged to contact ATF for further guidance on how they may divest possession. If you are uncertain whether the device you possess is a machinegun as defined by the GCA and NFA, please contact your local ATF Field Office. You may consult the local ATF Office’s webpage for office contact information.

Digitally signed by George Lauder,
Assistant Director Enforcement Programs and Services
Assistant Director Field Operations

___________

Noting that they say that "some after-market triggers have similar components but also incorporate a disconnector or similar feature to ensure that the trigger must be released before a second shot may be fired and may not be machineguns," I'm wondering why they didn't list those specifically found to be "machineguns" or if this is just getting the ruling out there so firearms owners can rush to get into compliance. A little more googling seems to make it look like this may affect "Rare Breed Triggers" but it looks like it might affect binary triggers, too.

Any thoughts?

Fuck the ATF.

quote:

Originally posted by Skull Leader:
Fuck the ATF.

What he said.

'Based on the ATF's determination'...

Translation: We made shit up...It what we do!

Yep, Fuck the ATF and all the .gov's at this point. I have busted my ass and my bank account trying to satisfy their regulations all while they refuse to enforce laws the left don't care to follow. I'm back to free men don't ask permission...

ATF "How dare you find a loop hole in our convoluted bullshit excuse for rules, in that case, we will just change the rules to screw you freedom lovers over."

Here's a link to a video (sorry, couldn't embed it) from the "TheMachineGunNest" YouTube channel from January 28 that discusses the issue and shows how the Rare Breed Trigger works.

https://youtu.be/01Z0GWGAZr4

TheMachineGunNest video on Rare Breed Trigger Issue

It looks like "Wide Open Trigger" from Bid Daddy Unlimited is type of FRT trigger that ATF has been reviewing, but as I noted earlier, in typical bureaucratic fashion, they haven't actually listed the ones they're ruling against.

Their wording is still wrong if you want to take it literally. "ATF’s position is that any FRT that allows a firearm to automatically expel more than one shot with a single, continuous pull of the trigger is a “machinegun”,". They say nothing about releasing the trigger (which is not a continuous pull of the trigger). So, I would argue that if I keep a "continuous pull" on the trigger it will only fire 1 single round. It does not go full auto. IANAL but still sounds like the original definition of a machine gun. Last time I checked wording is everything. There has got to be something that I missed while reading.

I think with the RB and WOT versions, you cannot keep the trigger depressed. Seems like the mechanism forces the trigger to move forward, and that’s what resets it. I am curious if one can even hold the trigger back firmly enough to defeat the forced reset?

quote:

Originally posted by sig226fan:
Their wording is still wrong if you want to take it literally. "ATF’s position is that any FRT that allows a firearm to automatically expel more than one shot with a single, continuous pull of the trigger is a “machinegun”,". They say nothing about releasing the trigger (which is not a continuous pull of the trigger). So, I would argue that if I keep a "continuous pull" on the trigger it will only fire 1 single round.

I believe you might be conflating forced reset triggers with binary triggers.

With a FRT, you cannot "pin" the trigger to the rear to only fire one round, like you can with a standard trigger or a binary trigger.

This deals with forced reset triggers. With these, the gun fires when the trigger is pulled, then the trigger forces itself forward during cycling. With a FRT, you can pull rearward on the trigger once, maintain that continuous rearward pressure, and empty the magazine as the trigger rapidly mechanically resets and fires despite your constant rearward trigger pressure. ATF's position is that with one continuous rearward pull by the finger but multiple bullets fired, it becomes a machine gun.

You may be envisioning binary triggers, where the finger pulls the trigger back to fire one bullet, and then the finger releases it to fire one bullet again. Those would not be affected here.

Faggots

.

Thanks, Greymann. That was the video I tried to embed which shows the Rare Breed Trigger's operation and has a good bit of discussion on the issue prior to this ruling.

quote:

Originally posted by RogueJSK:

quote:

Originally posted by sig226fan:
Their wording is still wrong if you want to take it literally. "ATF’s position is that any FRT that allows a firearm to automatically expel more than one shot with a single, continuous pull of the trigger is a “machinegun”,". They say nothing about releasing the trigger (which is not a continuous pull of the trigger). So, I would argue that if I keep a "continuous pull" on the trigger it will only fire 1 single round.

I believe you might be conflating forced reset triggers with binary triggers.

With a FRT, you cannot "pin" the trigger to the rear to only fire one round,…

You may be envisioning binary triggers, where the finger pulls the trigger back to fire one bullet, and then the finger releases it to fire one bullet again. Those would not be affected here.

RogueJSK, you are exactly right. I was thinking of binary triggers and how they work. Have not messed with either, and apparently was ignorant of the “Forced” portion of this. Thought it just helped you let off the trigger faster, and not throw your finger back to make you reset if you did not want to. Thanks for the info.

Doesn’t mean the AFT aren’t still assholes.

I'm tempted to pick up one of these just to fund Rare Breed.

I played with a Rare Breed in a store, not installed in a lower, just on its own. The cocking of the hammer forces the trigger forward. You cannot prevent it with finger pressure and you do not have to let up at all. Maybe someone with very very strong fingers could hold it hard enough to jam up the action on recoil, but I doubt it.

The Big Daddy Unlimited Wide Open Trigger seems to be better designed and built than the Rare Breed. But I have nowhere to shoot anything that will resemble full auto - no range near me will allow it. Binaries are OK because they are a fast double tap if you don't "run" them.

When I first saw the Rare Breed Trigger, I noticed it utilized a "3rd Pin" and wondered how long it would last under ATF ruling.

I'm not agreeing with the ATF, but honestly surprised it got approval in the first place.

quote:

Originally posted by Gibb:
When I first saw the Rare Breed Trigger, I noticed it utilized a "3rd Pin" and wondered how long it would last under ATF ruling.

I'm not agreeing with the ATF, but honestly surprised it got approval in the first place.

RBT never submitted theirs for ATF approval initially. They claim they proceeded based on an earlier ATF approval letter from 2013 for the Tac-Con 3MR trigger, a somewhat similar but separate (and patented) design manufactured by a different company, as well as the opinions of several former ATF agents that RBT had consulted.

Importantly, the 3MR is reportedly not a "forced" reset trigger, it's an "assisted" reset trigger that still requires the trigger finger to cease its rearward pressure in order to reset the trigger. It just creates a super short/quick trigger reset. Whereas the RBT is a true forced reset trigger that causes the trigger to mechanically reset regardless of trigger finger pressure, thus allowing one instance of continuous rearward pressure to repeatedly fire the rifle.

Thus ATF's stance of illegal automatic fire (RBT) vs. legal rapid semiauto fire (3MR).


However, RBT appears prepared to fight this in court. It'll take a while, because nothing about the court system ever moves quickly, but this is ultimately going to end up coming down to what the court rules after both sides present their arguments.

Is the trigger reset forced or assisted?

I got this info in an email from the ATF the other day. Which threw me because I don’t recall ever giving the ATF my email.