These are all serious and vital points, but there is another series of observations that begin on page 27 of the comment file that elaborate on concerns about the role of the NFATCA, and specifically the relationship of its president with ATF.
“Docket entry ATF-2013-0001-0437 [view] is a public comment submitted by John Brown, apparently the very same John Brown who, as President of National Firearms Act Traders and Collectors Association (‘NFATCA’), submitted the petition to initiate a rulemaking on which ATF purports to base this proceeding,” FICG relates. “Repeated efforts to ascertain from Mr. Brown the details of the incidents as to which he asserts he has knowledge met refusals as he disavowed direct, personal knowledge stating only that as a result of ‘working inside ATF for over 10 years’ he knew things he ‘should never know.’"
“[I]t would thus appear that ATF is itself the source of this information,” FICG infers. “The planting of comments that merely repeat to ATF the very information ATF purports to have but refused to submit to public critique exacerbates the problem of ATF's refusal to provide underlying information.
“Mr. Brown's connection to ATF extends beyond his acknowledgment that the information to which he alluded in his comment came from ATF itself,” FICG continues. “Indeed, as Richard Vasquez -- ATF's Chief of the Firearms Training Branch and previous Assistant and Acting Chief of the Firearms Technology Branch -- testified under oath only last year, Mr. Brown ‘interacted with ATF a lot,’ was a friend since at least 2006, had personally transferred two firearms to him, had transferred firearms to other ATF employees, visited ATF ‘to meet and become personal with a lot of the offices’ over a period of years, and provided him with information to pass along to ATF for ATF's use in a forfeiture proceeding.
“Mr. Brown apparently went so far as to forward e-mails he had received from a FFL involved in litigation with ATF to ATF for ATF's use in the litigation against the FFL,” the FICG narrative continues. “Indeed, Mr. Brown was not surprised to be characterized as a ‘confidential source’ for Acting Chief Vasquez and ATF.