ATF decides Honey Badger AR Pistol is SBR

[delcrossv]

Q, maker of the "Honey Badger" AR style pistol as received a letter from the ATF saying that the Honey Badger is no longer considered a pistol but a SBR. Of note, this letter was issued WITHOUT following the procedures of the APA (Administrative Procedures Act)

Please see the link below. Since ATF is an Executive branch organization, it probably make the most sense if members call the White House directly and ask for the President to intervene.
Here's the numbers:
Comments: 202-456-1111
Switchboard: 202-456-1414

BREAKING: ATF Issues Cease And Desist For Honey Badger PistolThe Firearm Blog

[Telecaster]

Is it a rifle having a barrel or barrels of less than 16 inches in length?

Is it a weapon made from a rifle if such weapon as modified has an overall length of less than 26 inches or a barrel or barrels of less than 16 inches in length?

[03hemi]

At this point they've ONLY called out "Q," the maker of the "Honey Badger" because it has their own version and proprietary pistol brace that is in question. They probably didn't get it approved through the ATF like the one's that are approved being used. We'll see, but you can't just stick your version of something on unless it's approved also.
EDIT: I've since learned that Q's brace was indeed approved by the **eff, it was/is supplied by SB Tactical and used on other AR pistols still in production. They were singled out by a rogue field agent apparently.

[Loyaljeeper]

I agree. The Honey Badger brave doesn’t even like like a usable brace or cheek weld. With that said, I really like my shockwave. I wouldn’t have a problem using it on a 16” barrel in place of a stock.

[SAFireman]

From reading the material provided, it appears that the ATF doesn't buy the pistol brace as such. If they re-submitted with an actual functioning brace, then maybe this would go away.

[delcrossv]

Originally Posted by Telecaster

Is it a rifle having a barrel or barrels of less than 16 inches in length?

Is it a weapon made from a rifle if such weapon as modified has an overall length of less than 26 inches or a barrel or barrels of less than 16 inches in length?

The question turns on "is it a rifle" or is it a pistol?

[Gamecock]

Time to amend the NFA. Remove restrictions on SBRs and "sawed off shotguns." As well as silencers. They are not unreasonable threats to society.

[BillBond]

The title of this thread is misleading.
The ATF is only going after one brand of AR pistol.

[bushmaster1313]

Yet another application of the adage: Be careful out there

[Telecaster]

A rifle is braced against the shoulder. Can these things be fired that way?

One could say a rifle can be fired other than from the shoulder (i.e. from the hip commando style), but a pistol AR can probably be fired in ways other than lashed to your arm...

It's all just pointless stupid arbitrary rules.

[delcrossv]

Originally Posted by BillBond

The title of this thread is misleading.
The ATF is only going after one brand of AR pistol.

So far. Lowest hanging fruit. If one thinks such a ruling if allowed to stand unopposed won't be extended to other braced pistols, he's in for a rude shock.

I too fail to see the efficacy of making SBRs scheduled items.

[Borderboss]

I think the problem with the Honey Badger is that the "brace" is adjustable for length. Every other brace I've seen is fixed. The Honey Badger brace may as well be an adjustable carbine stock. I'll bet a dollar that's how the ATF saw it.

I'm not worried about my AR pistol with my fixed brace.

[03hemi]

Nope, a lot of braces that have been ATF approved for years have always been collapsible. However, Q's doesn't even look like you could get an arm through it, it's a blatant schnut kicker on purpose.

[Dieseltech56]

There word through the grape vine a few months ago that the ATF was thinking about going after pistol braces. This is just the beginning.

[03hemi]

It doesn't matter in the end, people will just separate the upper and lowers and file a form one and re-classify it as an SBR if they do an all out reversal on the brace. This talk has been going around for several years.

[andy52]

Originally Posted by Dieseltech56

There word through the grape vine a few months ago that the ATF was thinking about going after pistol braces. This is just the beginning.

Sure hope your wrong because my .300 blackout pistol isn't set up much different then the Honey Badger with the SB Tactical PDW brace.

[03hemi]

Originally Posted by andy52

Sure hope your wrong because my .300 blackout pistol isn't set up much different then the Honey Badger with the SB Tactical PDW brace.

Completely different because 1) it was already approved and 2)you can actually get your arm through it. The Honey Badger was never approved first, not to mention, you can't get your arm through it either.

[Dieseltech56]

Congressman Matt Gaetz sounded the alarm on a secret brace ban back in June.

[delcrossv]

Originally Posted by 03hemi

It doesn't matter in the end, people will just separate the upper and lowers and file a form one and re-classify it as an SBR if they do an all out reversal on the brace. This talk has been going around for several years.

and pay $200 for the "privilege"

I'm just waiting to see what infringement finally gets some folks screaming.

Ho Hum, it's just an automatic
Ho Hum, it' just a large magazine
Ho Hum, it's just a brace
.....
Ho Hum, it's just a semiauto
Ho Hum it's just a revolver

And then there'll be nothing left to ho hum about.

[03hemi]

Oh well, whatcha gonna do? I won't be giving up my braced pistols, so I guess I'll pay the tax stamp.

[Sistema1927]

Look a the Q Honey Badger with the "brace" fully extended. The LOP is quite long. My understanding is the Q didn't get prior ATF approval of their "brace" setup, and have a sneaking suspicion that they were trying to see just how far they could go.

[BSA1]

If it looks like a duck, quacks like a duck, then is a ???.

The title of the topic is untrue but is good click bait. Peoples arms and forearms come in all sorts of different sizes and strength to hold weight. Q’s “brace” is not only made of hard polymer but they didn’t even make it curved on the inside to help give it a better fit.

Fyi I have a SBA3 brace and realize that redefining it to be a SBR is a risk I assumed when I brought it.

[ISCS Yoda]

Originally Posted by BSA1

If it looks like a duck, quacks like a duck, then is a ???.

The title of the topic is untrue but is good click bait. Peoples arms and forearms come in all sorts of different sizes and strength to hold weight. Q’s “brace” is not only made of hard polymer but they didn’t even make it curved on the inside to help give it a better fit.

Fyi I have a SBA3 brace and realize that redefining it to be a SBR is a risk I assumed when I brought it.

The title of this thread is misleading.
The ATF is only going after one brand of AR pistol.

Who didn't see this coming? So the Honey Badger has some weird little gimlet of a difference from other braced AR pistols. Oops. Do you think the ATF is going to stop there, with Gabby Gifford and her ilk pushing them (she started this, I think, or her group did).

The good news is that if there is going to be a fight let it be on technicalities and definitions and not because some whacko sneaked one of these into a theater and killed 40 people. That was always my concern.

And, yes, the law needs to be changed, deleted, whatever - when the GOP has both houses again, and the White House, then, MAYBE. Otherwise, no matter how reasonable, and there is a reasonable new bill in progress, it's not going to get through the HofR.

Here's fun question for you - if the ATF outlaws AR pistols what do you do with yours?

Follow up - if the ATF decides that any AR pistol with an arm brace is an AOW and requires a tax stamp will you get one? $5 or $200 - what will you do?

[Turn4811]

I do not like this. I have an AR-9 pistol that has an 11.5" barrel. It is fitting through the loophole but it was legal when I built it and it is legal now. There was a time it was not legal. Fun to shoot and stupid accurate.

[Muss Muggins]

Is there pending legislation regarding this issue?

[delcrossv]

Originally Posted by Muss Muggins

Is there pending legislation regarding this issue?

Yep.

Text - H.R.5289 - 116th Congress (2019-2020): Home Defense and Competitive Shooting Act of 2019 | Congress.gov | Library of Congress

[SweetMK]

I Googled "Honey Badger", and this was the first pic I saw at the "Q" website,

IMHO, that brace would strap to my arm,,,



Maybe HB is coming around?

[Borderboss]

Watching a YouTube video by MrGunsAndGear, this might be the case of a rogue field agent in Boston being a Trump hater and trying to get gun owners hating on Trump. Field agents never issue these kinds of rulings. So stay tuned.

[shocker]

Originally Posted by SweetMK

I Googled "Honey Badger", and this was the first pic I saw at the "Q" website,

IMHO, that brace would strap to my arm,,,



Maybe HB is coming around?

I read on another forum the "LOP" on a brace can't be more than 13.5", extended.
AFAIK, the blade type braces have passed muster as long as they are short enough.
I put a SBA brace on a 20 gauge Shockwave but decided I liked the ergonomics of the birdshead grip much better.

[steelslaver]

Originally Posted by Gamecock

Time to amend the NFA. Remove restrictions on SBRs and "sawed off shotguns." As well as silencers. They are not unreasonable threats to society.

I agree, but thats not going to happen.

Just loo at simple suppressors. They are just an attachment. The law doesn't stop a single person bent on murder, they do save hearing. Yet the legislation the make them an non issue went no where except the garbage cans.

[03hemi]

Watch the interviews between Colion Niore and the owner of PDW Brace and then the one with the owner of Q.

[robvious]

it would be nice to have a rule book everyone can follow...
without that it is just targeted arbitrary enforcement...
I have always had difficulty with "because I say so" from anyone...

[Mrnurse]

Brace, no Brace, ATF, KGB, LMNOP, Come and take it. Folks either your Free or a Slave. ATF OK's something Honest folks abide by, then arrest them when they change the law...Like the 1980's Street Sweepers, M14 receivers re-welded, Bump stocks etc. Me...Na Im done.... No more giving in.... come take them.

[Borderboss]

Originally Posted by Mrnurse

Brace, no Brace, ATF, KGB, LMNOP, Come and take it. Folks either your Free or a Slave. ATF OK's something Honest folks abide by, then arrest them when they change the law...Like the 1980's Street Sweepers, M14 receivers re-welded, Bump stocks etc. Me...Na Im done.... No more giving in.... come take them.

Yup, same here.

[robvious]

take the stock.. oops... brace off... its a pistol... why you got it in the first place.. not that anyone was trying to skate thru a loophole

[BC38]

Originally Posted by robvious

take the stock.. oops... brace off... its a pistol...

Yup. If I have to I can take the brace off in about 2 minutes.

[scooter123]

Go to almost any public range where AR's are seen in use and you'll see that most, as in almost all, Pistol AR's are shot with the arm brace against the shoulder. This is a usage that Violates the intent of the prior ATF rulings that Arm Braces may be mounted on a Pistol. At some point I fully expect that the ATF will issue a ruling that Arm Braces aren't legal and instantly turn a lot of AR pistols into SBR's. All because those who currently own these variants won't even be a tiny bit discrete about how these arm braces are used.

That said in this particular case the reason for this ruling is very obvious. I have always had smaller wrists and skinny forearms, enough so that I can reach areas in an engine compartment that would have others pulling the engine to get to. Looking at the pics of this pistol it appears to me that there is absolutely no chance at all that I could slide my arm thru that "arm brace". If Q mfg had made even a tiny attempt to make this an actual arm brace this would not have happened. So the blame for this ruling is on Q, they should have built that stock (oops, arm brace) so that it actually could be used as an arm brace by a grown adult.

[steelslaver]

Although I truly believe that the Bill of Rights was meant to follow MNurse's definitions, at this point it is kind of like believing in Santa Claus for all the good it does.

If the any of the Alphabets ever show up at your home with a warrant, it won't matter is the "brace" is on or off. They are going to find something that they can prosecute you for. By the time it is over your guilt or innocence isn't going to matter all that much. Unless your real rich to start out, your going to be broke and even rich guys who oppose the regime in power often find themselves broke or behind bars. At many of our ages, the difference between prison and a low dollar retirement home isn't all that great.

I don't have much use for the AR type "pistols" the braces, bump stocks, or any of those other deals. What I do have is a firm belief that the right to keep and bear arms isn't about duck hunting or target shooting.

The BATF or any other Alphabet doesn't get to have a free hand in making up laws and deciding what they mean. Neither does congress or even the President.

To me the 2nd means if you want a Ma duce mounted on top your car when you drive through McDonald's you should be able to have one, if it goes under the low clearance deal.

If a person doesn't believe in the true meaning of the US Constitution and Bill of Rights they should not be in government.

I still can dream can't I?

[03hemi]

The **eff released a letter about two years ago reversing their previous ruling you could not shoulder the brace because it was so silly, stating doing so did not change the intentional design of the brace. Sorta like, you can take your car on a NASCAR track, but that doesn't turn it into a race car.
Q's brace is/was approved by the feds and manufactured by SB tactical, the same brace is used on other pistols from other larger companies, but a field agent (that doesn't have this authority) issued the cease and desist letter to Q. It will be overturned I'm sure because (he) singled out this one company. It's all about politics and it's about to get ugly.
Bottom line, if your pistol measures 13.5" or less from the trigger to the back of the extended brace you're legal (provided your barrel is of legal length or less). The filed agent intentionally fudged these measurements and based his decision on that. (he purposely measured at an angle to come up over).
All this is in the two interviews with Colion Niore, I urge y'all to watch them.

[ladder13]

I’ve said this for as long as I can remember, “I believe in the 2A as written”.

[LoboGunLeather]

Originally Posted by robvious

it would be nice to have a rule book everyone can follow...
without that it is just targeted arbitrary enforcement...
I have always had difficulty with "because I say so" from anyone...

I view the problem differently. The laws enacted should be clear and specific, allowing everyone to know with certainty which specific acts are prohibited. Instead, laws are passed containing authorization for appointed bureaucrats to issue regulations which have the force of law. Subjective interpretations are bad enough, but interpretations that may be changed arbitrarily are much worse.

Of course, doing things this way allows those responsible to place all blame on others. Perhaps the reason?

[bulletslap]

The ATF has “Ruled” a shoe lace is a machine gun, so anything is possible.

The NFA control of SBRs is a vestige of the original NFA intent to control handguns and should be done away with.

[BB57]

Originally Posted by LoboGunLeather

I view the problem differently. The laws enacted should be clear and specific, allowing everyone to know with certainty which specific acts are prohibited. Instead, laws are passed containing authorization for appointed bureaucrats to issue regulations which have the force of law. Subjective interpretations are bad enough, but interpretations that may be changed arbitrarily are much worse.

Of course, doing things this way allows those responsible to place all blame on others. Perhaps the reason?

You have the right idea but it's more complicated than that.

Laws are written by legislators (or more often their young energetic and mostly clueless aides) with a lot of input from lobbyists.

Your statement is a situation where "be careful what you ask for applies in spades. Most laws as written are either not enforceable or would end up prohibiting things that were not intended to be prohibited even more than the current process. Plus the current process has some checks and balances in it as well as a requirement for public comment and input.

Ideally, how it works is that a law is introduced in both houses, reconciled in both houses to resolve any differences, and the reconciled bill is then passed on both houses.

Once that happens the law is sent to the cognizant federal agency to write the regulations that will implement the law. Again, ideally, the federal agency will have program experts who understand the thing being regulated write regulations that:
I) reflect the intent of congress;
II) make sense to the program or thing being regulated and the people who use the program or thing; and
III) Describe the law and how it is enforced with useful examples and definitions that fully describe the law, but don't go beyond it into what is termed "over reach".

Once the proposed regulations are written they are published in the federal register for a 60 day (minimum) public comment period. They proposed regs are accompanied by preamble language that explains the rationale for the proposed regulations and the language used.

Public comment is then received and changes are made in the regulations to reflect the concerns and problems that are noted in the public comments and the final regs are then published for a 30 day comment where the federal agency then response to each comment (they can be grouped by content) and explains what changes, if any were made based on the comments.

Once the regulations become final, ANY change in interpretation of the regulations that substantially changes the effect of the regulations REQUIRES a new public comment period.

-----

The above is the ideal. Here's where it sometimes runs off the rails:

1) In the US we produce far more attorneys than we can ever use, even chasing ambulances in our already tort ridden legal system. The surplus often go work for Federal agencies where they think their knowledge of the law will be very useful in writing and interpreting regulations. It usually isn't.


2) Those legally trained staff almost always lack any real program expertise and know very little about the program or issue being regulated. Consequently, unless there are very clear committee notes from congressional hearing talking about exactly what the new law is supposed to regulate and how, those legally trained staff with no program knowledge tend to fall back on a "narrow read of the law" to determine congressional intent.


3) They double down on that lack of knowledge by ignoring the subject matter experts in the agency that do know how things work and what makes sense in the field. They do that because they value a narrow read of the law more than actual knowledge or even common sense.


4) Those legally trained not so knowledgeable staff also know they don't know much about the program or issue, so they tend to be very risk averse and want to stay very close to the language written in the law.

In fact you'll often find regulations that just regurgitate what was written in the statute. That's parly what you asked for, and when the statutory language is poor, the result is equally poor, but then things work right it's where a functional federal agency run by knowledgeable people can turn a poorly written law into something that actually works.

This is also made worse in departments where senior leaders ask their offices of general counsel (actual practicing attorneys) "what should we do" rather than the correct question of "this is what we need to do, tell us how to make it defensible. When you ask an attorney "what should I do, he or she will ALWAYS the most conservative and most risk averse answer. That will almost always be something that is *not* in the best interest of performance, serving the public, etc.


5) To make matters even worse, given fairly quick deadlines to get the regs published, the regs for complex laws are written in separate pieces by those not very knowledgeable staff on separate committees. When that occurs you invariably end up with massive inconsistencies within a particular law and implementing regulations, but also with other laws and implementing regulations. Those conflicts cause all kinds of enforcement issues.


6) There is also the problem of federal agencies ignoring public comments. It's most often a case of lack of knowledge and/or being risk averse. Sometimes it's just a case of an administration pushing a specific agenda, and wanting to force something into regulation even though it doesn't reflect the will of the public.

What you'll see in the second public comment period is comment after comment with "we disagree with the commenters" and/or "we made no change to the language". In fact you'll see regulations with hundreds of negative public comments where the federal agency made no change at all in the proposed regs. At that point it's just an agency going through the motions and not honoring those comments. Unfortunately, while there is a requirement to publish regs for public comment, there is no requirement that a federal agency actually change a thing based on that comment.

7) Finally, there is also the problem of regulatory overreach. That occurs at two points in time.

First, it can happen when a law is initially implemented when the legally trained staff above take an overly narrow and risk averse read of the law and go way beyond the intent of congress in writing the regulations.

Second and more often, it is usually the result of an administration or it's political appointees deciding to reinterpret a long standing regulation.

The second, is a legitimate thing to do *IF* they open it up for public comment *AND* honor those comments by either revising or dropping the proposed change in interpretation.

A few years ago that happened when the ATF decided to ban M855 ammo by reinterpreting the regs to identify it as "armor piercing" ammunition. However, they received over 97,000 negative comments on that proposed change and they dropped it.

----

The things that would improve the process are:

A) better thought out and better written statutes coming from congress;

B) political appointees and and cabinet level officials who actually are experts in their fields rather than political hacks and loyalists;

C) a law requiring public comment to be considered and reflected in revised final regulations;

D) hiring standards that either out and out require field experience, or give it a huge amount of preference in hiring, and and career ladders that *REQUIRE* field experience to advance to management positions; and

E) enforcement of the law requiring any significant change in interpretation of a regulation go out for public comment.

[steelslaver]

Originally Posted by BB57

Y
The things that would improve the process are:

A) better thought out and better written statutes coming from congress;

B) political appointees and and cabinet level officials who actually are experts in their fields rather than political hacks and loyalists;

C) a law requiring public comment to be considered and reflected in revised final regulations;

D) hiring standards that either out and out require field experience, or give it a huge amount of preference in hiring, and and career ladders that *REQUIRE* field experience to advance to management positions; and

E) enforcement of the law requiring any significant change in interpretation of a regulation go out for public comment.

True , but until Santa brings me that pony I won't look for any of that to happen

Don't get me wrong. I am pretty sure you are correct in how it really works for the most part. I also agree with you on how it should work. But, I gave up on thinking that the government should or would do all that much in a sensible manner.

Most of those in Government have never had a job that actually produced anything tangible except for tons of scrap paper

[LVSteve]

Quite honestly I'm surprised that the "long pistol braces" on "pistols" have lasted this long without the ATF getting uppity.

This also reminds us that there is a bunch of legacy stuff in the NFA that needs to go away.

[LoboGunLeather]

Originally Posted by BB57

You have the right idea but it's more complicated than that.

Laws are written by legislators (or more often their young energetic and mostly clueless aides) with a lot of input from lobbyists.

Your statement is a situation where "be careful what you ask for applies in spades. Most laws as written are either not enforceable or would end up prohibiting things that were not intended to be prohibited even more than the current process. Plus the current process has some checks and balances in it as well as a requirement for public comment and input.

Ideally, how it works is that a law is introduced in both houses, reconciled in both houses to resolve any differences, and the reconciled bill is then passed on both houses.

Once that happens the law is sent to the cognizant federal agency to write the regulations that will implement the law. Again, ideally, the federal agency will have program experts who understand the thing being regulated write regulations that:
I) reflect the intent of congress;
II) make sense to the program or thing being regulated and the people who use the program or thing; and
III) Describe the law and how it is enforced with useful examples and definitions that fully describe the law, but don't go beyond it into what is termed "over reach".

Once the proposed regulations are written they are published in the federal register for a 60 day (minimum) public comment period. They proposed regs are accompanied by preamble language that explains the rationale for the proposed regulations and the language used.

Public comment is then received and changes are made in the regulations to reflect the concerns and problems that are noted in the public comments and the final regs are then published for a 30 day comment where the federal agency then response to each comment (they can be grouped by content) and explains what changes, if any were made based on the comments.

Once the regulations become final, ANY change in interpretation of the regulations that substantially changes the effect of the regulations REQUIRES a new public comment period.

-----

The above is the ideal. Here's where it sometimes runs off the rails:

1) In the US we produce far more attorneys than we can ever use, even chasing ambulances in our already tort ridden legal system. The surplus often go work for Federal agencies where they think their knowledge of the law will be very useful in writing and interpreting regulations. It usually isn't.


2) Those legally trained staff almost always lack any real program expertise and know very little about the program or issue being regulated. Consequently, unless there are very clear committee notes from congressional hearing talking about exactly what the new law is supposed to regulate and how, those legally trained staff with no program knowledge tend to fall back on a "narrow read of the law" to determine congressional intent.


3) They double down on that lack of knowledge by ignoring the subject matter experts in the agency that do know how things work and what makes sense in the field. They do that because they value a narrow read of the law more than actual knowledge or even common sense.


4) Those legally trained not so knowledgeable staff also know they don't know much about the program or issue, so they tend to be very risk averse and want to stay very close to the language written in the law.

In fact you'll often find regulations that just regurgitate what was written in the statute. That's parly what you asked for, and when the statutory language is poor, the result is equally poor, but then things work right it's where a functional federal agency run by knowledgeable people can turn a poorly written law into something that actually works.

This is also made worse in departments where senior leaders ask their offices of general counsel (actual practicing attorneys) "what should we do" rather than the correct question of "this is what we need to do, tell us how to make it defensible. When you ask an attorney "what should I do, he or she will ALWAYS the most conservative and most risk averse answer. That will almost always be something that is *not* in the best interest of performance, serving the public, etc.


5) To make matters even worse, given fairly quick deadlines to get the regs published, the regs for complex laws are written in separate pieces by those not very knowledgeable staff on separate committees. When that occurs you invariably end up with massive inconsistencies within a particular law and implementing regulations, but also with other laws and implementing regulations. Those conflicts cause all kinds of enforcement issues.


6) There is also the problem of federal agencies ignoring public comments. It's most often a case of lack of knowledge and/or being risk averse. Sometimes it's just a case of an administration pushing a specific agenda, and wanting to force something into regulation even though it doesn't reflect the will of the public.

What you'll see in the second public comment period is comment after comment with "we disagree with the commenters" and/or "we made no change to the language". In fact you'll see regulations with hundreds of negative public comments where the federal agency made no change at all in the proposed regs. At that point it's just an agency going through the motions and not honoring those comments. Unfortunately, while there is a requirement to publish regs for public comment, there is no requirement that a federal agency actually change a thing based on that comment.

7) Finally, there is also the problem of regulatory overreach. That occurs at two points in time.

First, it can happen when a law is initially implemented when the legally trained staff above take an overly narrow and risk averse read of the law and go way beyond the intent of congress in writing the regulations.

Second and more often, it is usually the result of an administration or it's political appointees deciding to reinterpret a long standing regulation.

The second, is a legitimate thing to do *IF* they open it up for public comment *AND* honor those comments by either revising or dropping the proposed change in interpretation.

A few years ago that happened when the ATF decided to ban M855 ammo by reinterpreting the regs to identify it as "armor piercing" ammunition. However, they received over 97,000 negative comments on that proposed change and they dropped it.

----

The things that would improve the process are:

A) better thought out and better written statutes coming from congress;

B) political appointees and and cabinet level officials who actually are experts in their fields rather than political hacks and loyalists;

C) a law requiring public comment to be considered and reflected in revised final regulations;

D) hiring standards that either out and out require field experience, or give it a huge amount of preference in hiring, and and career ladders that *REQUIRE* field experience to advance to management positions; and

E) enforcement of the law requiring any significant change in interpretation of a regulation go out for public comment.

Excellent post! Thank you for your efforts and excellent communications skills.

[snuffy51]

I think I just get confused too easily. Kind of like "who's on first" type thing.

[Fastbolt]

Looking at the Honey Badger Carbine, with collapsible stock, and then looking at the Honey Badger collapsible "pistol brace" on the pistol ... it strikes me that ...

A rose, by any other name.

Might as well revisit the attempt to evade consequences by doing a little sidestep and protest ... "It depends how to define the word is" ...

Their collapsible Carbine stock and their collapsible "pistol brace" don't appear to significantly vary in form and function when looked at from the pistol brace/stock utility, meaning both would look to be as easily, and interchangeably, used as a stock. One has an open center and some looped fabric. Just calling one a brace, and putting a loop of material on it, may not prevent it from being as easily utilized as a stock as their Carbine collapsible stock. Is that just a convenient coincidence?

The company may have skated a bit too close to the edge to suit the involved regulatory agency. Skate too close to the fire, risk getting singed.

If other companies have managed to avoid this debacle with their "pistol brace" designs? Hmmm. How could this injury have been prevented?

[BigBill]

I traded in my evil rifles so I didn’t have to register them again. I figure they will tax the ones who own them next. God only knows how much I love our country. I pray things were normal again.
I really wanted an ak pistol but waited too long to get one. The bb and pellet guns look good, maybe next hobby.

[tazaroot]

Originally Posted by Borderboss

I think the problem with the Honey Badger is that the "brace" is adjustable for length. Every other brace I've seen is fixed. The Honey Badger brace may as well be an adjustable carbine stock. I'll bet a dollar that's how the ATF saw it.

I'm not worried about my AR pistol with my fixed brace.

I'm agreeing with you 100% that the cause for alarm with the fed boyz is that the "brace" is adjustable. No different than putting a six position telescopic stock on a regular AR pistol. I built my own AR pistol with a 7" barrel and decided to forgo the brace (don't like them) and put on a Phase 5 padded buffer tube.