"....The Department of Justice (the Department) has recently concluded that, as a matter of law, applying a more stringent State residency requirement for aliens legally present in the U.S. than for U.S. citizens is incompatible with the language of the GCA. As a result, ATF will be revising the regulations in 27 C.F.R. Part 478 to conform to the Department’s conclusions by removing the separate 90-day residency requirement for aliens. Once the regulations have been revised, both U.S. citizens and aliens legally present in the U.S. will be subject to the same requirements for State residency and proof of residency. ATF is in the process of amending its forms to conform to the statute as well.
`This process of amending the relevant regulations and forms will be completed as expeditiously as possible. Until that process is complete, however, the current regulations have the force of law. Accordingly, for the time being, FFLs should continue to use the current forms and abide by the current regulations.
ATF is committed to assisting you in complying with Federal firearms laws......"
