Earlier today, BATFE released an Open Letter on the Redesign of “Stabilizing Braces.” This letter articulates BATFE’s official position on the use of pistol stabilizing braces like the Sig Sauer SB15. It concludes that “[a]ny person who intends to use a handgun stabilizing brace as a shoulder stock on a pistol (having a rifled barrel under 16 inches in length or a smooth bore firearm with a barrel under 18 inches in length) must first file an ATF Form 1 and pay the applicable tax because the resulting firearm will be subject to all provisions of the NFA.”
According to the letter, BATFE finds that “[b]ecause the NFA defines both rifle and shotgun to include any “weapon designed or redesigned, made or remade, and intended to be fired from the shoulder,” any person who redesigns a stabilizing brace for use as a shoulder stock makes a NFA firearm when attached to a pistol with a rifled barrel under 16 inches in length or a handgun with a smooth bore under 18 inches in length.” It’s unclear how simply using a device in a certain way without altering it “redesigns” it, but the letter insists that BATFE “applie[d] the common meaning” of “redesign” in order to reach this conclusion.
To paraphrase Inigo Montoya, the letter keeps using the word “redesign.” We do not think it means what BATFE thinks it means.
Moreover, this conclusion is the exact opposite of advice that BATFE provided to individuals in private letters, the reasoning of which BATFE is now clearly abandoning. The new open letter stipulates that “[a]ny individual letters stating otherwise are contrary to the plain language of the NFA, misapply Federal law, and are hereby revoked.”
As with other recent rulings from BATFE, the letter does not seem to acknowledge (and perhaps its authors don’t understand) the full effect of its conclusion that use of a firearm in a particular way without alteration constitutes a “redesign” of that firearm. The only thing that is clear from the letter is that BATFE considers shouldering any pistol with a stabilizing brace as making a firearm subject to registration and other requirements under the National Firearms Act.
Another Week, Another Executive Gun Control Action: BATFE Reverses Prior Position on Pistol "Stabilizing Braces"

Friday, January 16, 2015

Monday, April 28, 2025
Once again, Chicago has provided a cautionary tale in gun control. This time the city helped to illustrate the futility of gun turn-ins – sometimes incorrectly termed “buybacks” by those under the misimpression that all ...
Monday, April 21, 2025
On April 16, Director of National Intelligence Tulsi Gabbard made good on a promise to expose the ways in which the Biden administration had weaponized the federal government against its political adversaries by releasing the Biden-era “Strategic Implementation Plan ...
Monday, April 28, 2025
On Monday, April 21, the U.S. Supreme Court declined to review an appeal from the state of Minnesota in Worth v. Jacobson, allowing to stand an Eight Circuit ruling declaring that a ban on obtaining carry permits by ...
Monday, April 28, 2025
As we wrote about last week, a cornerstone of the Biden administration’s “Strategic Implementation Plan for Countering Domestic Terrorism,” a plan aimed at curtailing Second Amendment rights under the guise of fighting domestic terrorism, was ...
Friday, March 21, 2025
On March 20, the U.S. Department of Justice (DOJ) published an interim final rule entitled, Withdrawing the Attorney General’s Delegation of Authority. That bland title belies the historic nature of the measure, which is aimed at reviving ...
More Like This From Around The NRA
