This is pretty much the way I see it. So, my question is, are they going to issue millions of FFL’s so we can acquire, sell and trade firearms and enhance our private collections? I doubt it. For years one of their goals was to deny or revoke licenses to small home dealers because they didn’t do a significant amount of business.
ATF will point to the ‘personal collection’ carveout and let you attempt to use that as a defense at trial.
The way this rule is written, with a presumption of guilt, will be litigated all the way to SCOTUS. ATF will state they simply wrote a rule that implements what is codified law, so it’s not out of the realm of possibilities that relevant portions of BPSCA will be declared unconstitutional. But that’s a long road to travel.