GunBroker Comments on Proposed ATF Remote Firearm Transfer Rule (RIN 1140-AB05)

GunBroker.com Comments on Proposed ATF Remote Firearm Transfer Rule Outdoor Holding Company, through its subsidiary GunBroker.com, recently submitted comments to the Bureau of Alcohol, Tobacco, Firearms and Explosives (“ATF”) regarding ATF’s notice of proposed rulemaking titled “Revising Non-Over-the-Counter Firearms Transaction Requirements” (RIN 1140-AB05). See https://www.regulations.gov/comment/ATF-2026-0266-2265 for the full comment letter. GunBroker’s business has long been built around helping federally licensed firearms dealers (“FFLs”) reach consumers, sell inventory and provide firearm transfer services. As of March 31, 2026 our marketplace had approximately 8.8 million registered users, featured approximately 4.43 million listings on a typical day, and provided access to a nationwide network of more than 32,000 FFLs. The proposed NOTC rule represents another potential way for GunBroker to help those dealers serve their customers. If adopted, qualifying FFLs could complete certain transfers to residents of their own state without requiring the purchaser to physically visit the dealer. The Proposed Rule would continue to require completion of Form 4473 and compliance with NICS background-check requirements, CLEO notification, the applicable seven-day statutory period, and all other applicable federal, state and local laws. It would also require a video conference with the purchaser and remote identity verification through a credential service provider whose processes satisfy specified NIST identity- and authentication-assurance standards. Importantly, the potential opportunity may extend beyond dealers selling their own inventory. GunBroker’s existing business model also connects buyers with local transfer dealers who complete transfers for firearms purchased from other sellers. In our comments, we asked ATF to clarify that an FFL that receives a firearm from another seller for transfer to the purchaser may use the NOTC process for the retail transfer, provided that the FFL and transaction otherwise satisfy all applicable requirements. Such an interpretation could allow participating transfer dealers to offer an additional service to consumers while preserving the licensed-dealer role at the center of the transaction. Our comments also recommend practical safeguards and implementation improvements, including workable CLEO notification procedures, strong privacy protections for purchaser information, competitive remote identity-verification options, and the ability for dealers to use third-party technology providers to help administer the compliance process. The comment period closed on August 6, 2026. There is no assurance that ATF will adopt the proposed rule, when a final rule might become effective, or whether the final requirements will resemble those proposed. If a final rule materially expands NOTC transactions, we also expect legal challenges that could delay implementation, potentially for a significant period. Accordingly, we do not currently assume any near-term financial contribution from the proposal. If ultimately implemented in a commercially workable form, however, we view NOTC transactions as an extension of what GunBroker already does: providing dealers with tools and access to consumers that help them sell firearms, perform transfers and offer additional services to their customers. The availability of NOTC transactions would also vary by state, and certain states restrict, or may be expected to prohibit, such transactions under existing or future state law. Rather than changing GunBroker’s business model, the rule could create another way for our dealer network to participate in and benefit from the GunBroker marketplace. See the full comment letter at https://www.regulations.gov/comment/ATF-2026-0266-2265. This communication contains “forward-looking statements” within the meaning of the Private Securities Litigation Reform Act of 1995, including statements regarding the proposed NOTC rule, its potential adoption, timing, final form and implementation, potential legal challenges, and the potential effects of any final rule on GunBroker’s business and the opportunities it may create for FFLs and consumers. Words such as “could,” “may,” “expect,” “view,” “potential” and similar expressions identify forward-looking statements. These statements are based on current expectations and assumptions and are subject to risks and uncertainties that could cause actual results to differ materially, including whether and in what form ATF adopts a final rule, the outcome of any legal challenges, changes in federal, state and local law, and the other risks described in the Company’s filings with the Securities and Exchange Commission, including its most recent Annual Report on Form 10-K and subsequent Quarterly Reports on Form 10-Q. Forward-looking statements speak only as of the date of this communication, and the Company undertakes no obligation to update them except as required by law.