BadBolt
10-17-2011, 06:36 PM
From Silencerco:
The NFA Branch: Poorly Structured and Bad for Business
Written by Silencerco on October 13, 2011 — 10 Comments
I feel the need to talk about government, politics, and the NFA. It must be because we are in the thick of a rapidly declining America with an unbelievably ridiculous president at the helm. Or maybe its because most people in our industry are politically savvy because we constantly have to fight for our right to keep and bare arms. Or maybe its because Silencerco is experiencing longer and longer wait times for form approval. Whatever the reason is, in which I feel so inclined to write about this topic, I know it is important to let you all know that trouble could be on the horizon. The NFA branch is experiencing our industryʼs rapid growth but they are decreasing the number of examiners, and not reacting to the growth in any way. This makes business hard for manufacturers and dealers.
A little History and How The NFA Branch Works
In 2010 there were 34,037 form 4 transfers processed by the NFA branch. There are only 12 examiners employed by the NFA branch to process those forms. That means that there are roughly 2,837 form 4 transfers to process per examiner. Assuming there is 250 workdays in the year (260 business days in the week minus 2 weeks of vacation time), that means each examiner has to process 11 to 12 form 4 transfers per day. Now here are some things to consider: for every form 4 there is a form 2 (manufacturers notifying the NFA that they manufactured a product) and a form 3 (dealer to dealer transfers or manufacture to dealer transfers) associated with the product being transferred. Also, there are form 5 (law enforcement or government agency transfers) and form 1 transfers (individuals making their own silencer) that were not included in the FOIA report this information is being pulled from, Nor is there any indication of how many form 1, 2, 3, 4, or 5 transfers are denied.
This means It is possible that each examiner has to process 30 to 50 forms per day! Maybe thats possible you say. Well think of it this way. In 2007 there was a total of 22,233 form 4 transfers processed that year. There was 12 examiners back then as well. If anyone remembers the good old days when the NFA would process a form 4 in 6-8 weeks those days are long past. The private ownership of NFA regulated items has grown substantially and its arguable that the law enforcement/government agency market has seen even more growth. So why are there not more examiners?
Some Questions For Our Dear Government
Lets think about some questions. In 2007 the NFA brach brought in $6.9M in revenue from tax stamps, in 2010 they brought in $9.7M. Where is this money going? Surely it does not cost $9.7 million dollars to pay 12 peopleʼs salary and pay rent and utilities for the building they occupy. Where is our hard earned money going? Is it going to fund Fast and Furious? Or pad Eric Holderʼs pockets? All Iʼm saying is it just doesnʼt add up. Lets assume that NFA examiners are inefficient and their jobs cost millions of dollars a year. Okay fine. However, in this day and age there is unbelievable technology that would do their jobs for them. Its called SOFTWARE! Why hasnʼt any been developed to streamline the transfer process? It would be more accurate and more efficient and would only take a fraction of their revenue to develop. Oh wait, I forgot, government and innovation cannot coexist. If every politician is crying about how they are going to create jobs, why are they not hiring more examiners? I know it will not fix our unemployment problems but at least there would be a few more people with jobs. A few more examiners would greatly help with faster form times and encourage people to buy more NFA regulated items. That would in turn create more revenue for the NFA branch of the ATF.
Click to view full size image
Lets Sum It Up
My fear is that wait times for NFA examiners to process forms gets so out of hand that it really hurts business worse than it already is. We are already seeing the hurt in many areas. When Silencerco started in 2008 our form 3 transfers were taking less than 2 weeks, they are now taking 6-8 weeks. That means that our inventory is sitting dead in the water. Dead inventory equals dead cash flow. At the rate of our current market expansion I estimate that form 4 transfers could be a year or longer if there are no additional examiners hired. How many people want to pay for a silencer and not be able to pick it up for a year? Its already bad enough at the current 4-6 months. This will really effect the business of manufacturers and dealers.
We pay taxes so that we get some type of benefit. Thats the idea anyways. Regulatory agencies do not help us or benefit us in any way. They stifle growth and frustrate markets. The ATF does not help us at all, I think we can all agree they are more problematic than anything with the recent Fast and Furious scandal. So if we are going to pay a $200 tax, I would hope that they can give us what we are paying for in a manner that satisfies the very people that give them their jobs.
How Can We Help?
Lets be more politically active. Write to your congressmen and government representatives.
Sign these petitions:
http://www.thepetitionsite.com/1/proper-appropriation-of-voluntary-tax-dollars-generated-by-the-nfa-branch-of-the-batfe/
and
https://wwws.whitehouse.gov/petitions/!/petition/petition-increase-manpower-and-system-efficacy-batfes-national-firearms-act-branch/qBq7wmNH
Keep your eye out for the upcoming American Silencer Association (ASA) that will be fighting for your rights.
Sign up to receive information and notifications here. http://www.americansilencerassociation.com
Please become a member when it officially launches. For a “silent” industry, lets make some noise.
The NFA Branch: Poorly Structured and Bad for Business
Written by Silencerco on October 13, 2011 — 10 Comments
I feel the need to talk about government, politics, and the NFA. It must be because we are in the thick of a rapidly declining America with an unbelievably ridiculous president at the helm. Or maybe its because most people in our industry are politically savvy because we constantly have to fight for our right to keep and bare arms. Or maybe its because Silencerco is experiencing longer and longer wait times for form approval. Whatever the reason is, in which I feel so inclined to write about this topic, I know it is important to let you all know that trouble could be on the horizon. The NFA branch is experiencing our industryʼs rapid growth but they are decreasing the number of examiners, and not reacting to the growth in any way. This makes business hard for manufacturers and dealers.
A little History and How The NFA Branch Works
In 2010 there were 34,037 form 4 transfers processed by the NFA branch. There are only 12 examiners employed by the NFA branch to process those forms. That means that there are roughly 2,837 form 4 transfers to process per examiner. Assuming there is 250 workdays in the year (260 business days in the week minus 2 weeks of vacation time), that means each examiner has to process 11 to 12 form 4 transfers per day. Now here are some things to consider: for every form 4 there is a form 2 (manufacturers notifying the NFA that they manufactured a product) and a form 3 (dealer to dealer transfers or manufacture to dealer transfers) associated with the product being transferred. Also, there are form 5 (law enforcement or government agency transfers) and form 1 transfers (individuals making their own silencer) that were not included in the FOIA report this information is being pulled from, Nor is there any indication of how many form 1, 2, 3, 4, or 5 transfers are denied.
This means It is possible that each examiner has to process 30 to 50 forms per day! Maybe thats possible you say. Well think of it this way. In 2007 there was a total of 22,233 form 4 transfers processed that year. There was 12 examiners back then as well. If anyone remembers the good old days when the NFA would process a form 4 in 6-8 weeks those days are long past. The private ownership of NFA regulated items has grown substantially and its arguable that the law enforcement/government agency market has seen even more growth. So why are there not more examiners?
Some Questions For Our Dear Government
Lets think about some questions. In 2007 the NFA brach brought in $6.9M in revenue from tax stamps, in 2010 they brought in $9.7M. Where is this money going? Surely it does not cost $9.7 million dollars to pay 12 peopleʼs salary and pay rent and utilities for the building they occupy. Where is our hard earned money going? Is it going to fund Fast and Furious? Or pad Eric Holderʼs pockets? All Iʼm saying is it just doesnʼt add up. Lets assume that NFA examiners are inefficient and their jobs cost millions of dollars a year. Okay fine. However, in this day and age there is unbelievable technology that would do their jobs for them. Its called SOFTWARE! Why hasnʼt any been developed to streamline the transfer process? It would be more accurate and more efficient and would only take a fraction of their revenue to develop. Oh wait, I forgot, government and innovation cannot coexist. If every politician is crying about how they are going to create jobs, why are they not hiring more examiners? I know it will not fix our unemployment problems but at least there would be a few more people with jobs. A few more examiners would greatly help with faster form times and encourage people to buy more NFA regulated items. That would in turn create more revenue for the NFA branch of the ATF.
Click to view full size image
Lets Sum It Up
My fear is that wait times for NFA examiners to process forms gets so out of hand that it really hurts business worse than it already is. We are already seeing the hurt in many areas. When Silencerco started in 2008 our form 3 transfers were taking less than 2 weeks, they are now taking 6-8 weeks. That means that our inventory is sitting dead in the water. Dead inventory equals dead cash flow. At the rate of our current market expansion I estimate that form 4 transfers could be a year or longer if there are no additional examiners hired. How many people want to pay for a silencer and not be able to pick it up for a year? Its already bad enough at the current 4-6 months. This will really effect the business of manufacturers and dealers.
We pay taxes so that we get some type of benefit. Thats the idea anyways. Regulatory agencies do not help us or benefit us in any way. They stifle growth and frustrate markets. The ATF does not help us at all, I think we can all agree they are more problematic than anything with the recent Fast and Furious scandal. So if we are going to pay a $200 tax, I would hope that they can give us what we are paying for in a manner that satisfies the very people that give them their jobs.
How Can We Help?
Lets be more politically active. Write to your congressmen and government representatives.
Sign these petitions:
http://www.thepetitionsite.com/1/proper-appropriation-of-voluntary-tax-dollars-generated-by-the-nfa-branch-of-the-batfe/
and
https://wwws.whitehouse.gov/petitions/!/petition/petition-increase-manpower-and-system-efficacy-batfes-national-firearms-act-branch/qBq7wmNH
Keep your eye out for the upcoming American Silencer Association (ASA) that will be fighting for your rights.
Sign up to receive information and notifications here. http://www.americansilencerassociation.com
Please become a member when it officially launches. For a “silent” industry, lets make some noise.