The Slippery Slope

Kurt weighs in on my piece from yesterday. [More]

I hope he doesn't take an grief from the controversy I'm trying to resolve.  Latest word from the lawyers I vetted mine with is:

UPDATE 2: I took the raised concern back to the attys I vetted this with and asked what we should make of "Extension without change of an existing collection." The answer: "I don't think anyone knows for sure, but as [name redacted] already stated, it is likely a precursor to a new rule being proposed."

A second replied “I do not see any information that limits the multiple rifle reporting to 'only' border states in the new collection. The OLD federal register actually stated only the border states. I believe this is going to apply to all FFLs."

And it does:

This requirement will apply only to Federal Firearms Licensees (FFLs) who are dealers and/or pawnbrokers in Arizona, California, New Mexico and Texas. 

The new one does not so limit things.