On March 24th the ATF released an open letter to all Federal Firearms Licensees in regards to the purchase, selling, and possession of Forced Reset Triggers or FRTs. Although this probably doesn’t come as a surprise to anyone, the letter is quite clear in its intention and seems to actively seek out to retroactively punish those who have purchased them or have sold them. The full letter has been posted below for your convenience.

More Letters from the ATF @ TFB:

• 80% AR-15 Lower Receiver Determination Letter from the ATF
• Is the ATF Mass Disapproving Home-Made Form 1 Suppressors?
• SILENCER SATURDAY #209: Solvent Trapped – The ATF Warning Letter

ATF Deems FRTs as “Machine Guns” in Open Letter to FFLs

March 24, 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. Alphonso Hughes Assistant Director Enforcement Programs and Services George Lauder Assistant Director Field Operations

This particular determination made by the above organization and individuals is quite threatening as it seems to me that it will retroactively make otherwise law-abiding citizens and FFL holders into felons almost overnight. However, it is anyone’s guess as to what “take appropriate remedial action” means in the context of those who have purchased or sold them legally. I’d like to hear your thoughts on this matter. What do you guys expect the next steps to be in this recent development in regards to FRT triggers? If you’re looking to catch up on this particular subject, TFBTV Executive Producer James Reeves had a great interview with Rare Breed Triggers President Lawrence Demonico which will bring you up to speed on what the company has faced so far with the ATF and the FRT-15 Triggers.