[The following document was submitted to the House Subcommittee on 
Treasury, Postal Service and General Government Appropriations by 
representatives of the Bureau of Alcohol, Tobacco and Firearms, including 
Kent M. Cousins, Gary N. Schaible, Walfred Nelson, ATF's General Counsel 
and Congressional Affairs Office, during a meeting held November 19, 
1999, at B-307 Rayburn House Building, at the request of the Subcommittee 
and of the House Committee on Government Reform.]

DISADVANTAGES OF AN ADDITIONAL GENERAL
AMNESTY REGISTRATION PERIOD

-- An amnesty would suspend enforcement of the NFA.  Pending 
investigations and prosecutions for violations of the NFA might have to 
be terminated.  There are now pending 298 defendants under indictment for 
violations of the NFA and another 638 persons being considered for 
prosecution by U.S. Attorneys offices.  These figures do not include 
those cases and investigations still pending at the end of FY 92.

-- Section 922(o), Title 18, U.S.C. prohibits the possession of 
machineguns not lawfully possessed prior to its effective date, May 19, 
1986.  The possession of any machinegun registered during a new amnesty 
period would still violate section 922(o).  With respect to 922(o), the 
law makes no provision for an amnesty.

-- Amnesty would provide the criminally inclined an opportunity to 
possess unregistered weapons with impunity.

-- Anyone, including felons, mental incompetents, and person whose 
possession of firearms would violate State and local laws, could register 
NFA weapons.

-- A new amnesty for registering machineguns, bombs, grenades, silencers, 
etc., will be perceived as a retreat by the Administration from its 
position of favoring stronger gun controls, _e.g._, banning the 
possession of semiautomatic assault weapons.

-- An upsurge in the making of NFA weapons, particularly short-barreled 
shotguns, can be expected as individuals seize the opportunity to acquire 
NFA weapons without incurring the $200 making tax.  Also, the $200 
transfer tax would be avoided by unlawful transfers to persons who would 
register the weapons during the amnesty.

-- Firearms imported with certain restrictions, such as for sales samples 
or law enforcement use only, would be transferred to persons who would 
register the weapons during the amnesty and circumvent the restrictions.

-- It would create ill-will on the part of persons who have been 
prosecuted for possession of unregistered NFA weapons, had their weapons 
seized, or voluntarily abandoned their weapons to ATF in the past.  

-- A new amnesty would reward those who have unlawfully stockpiled 
unregistered contraband in anticipation of registering them during a 
future amnesty and encourage people to retain or acquire unregistered 
firearms in the expectation of other such periods.

-- An additional amnesty would only be a temporary solution.  It would 
only be a matter of time before people would claim they did not know 
about the amnesty or did not realize they had an NFA weapon in their 
possession.