On June 13, 2025, the National Shooting Sports Foundation (NSSF), the gun industry’s trade association, announced that the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) will end its Demand Letter 2 program, an initiative the agency has used for 25 years to identify and monitor the gun dealers who sold the most crime guns across the country. As discussed below, the program also allows the ATF to trace used guns that end up at crime scenes, and without it, police will have one less crime-solving tool available to them.
Why the NSSF — a private organization — announced the end of a federal regulatory program before the agency itself remains unclear, but its reason for celebrating the decision is not. In its announcement, the gun group criticized the “misuse” of the program and efforts to “name and shame” gun dealers who sell high volumes of crime guns.
The decision to end the Demand Letter 2 program comes as the Trump administration considers slashing ATF staffing — including personnel who inspect gun dealers every year — and merging the agency with the Drug Enforcement Administration (DEA). Other moves by the Trump administration to rollback oversight of the gun industry are discussed below.
the demand letter 2 program
Since February 2000, the ATF has issued Demand Letter 2 to gun dealers with “frequent short time-to-crime traces,” or those who sold guns that were quickly recovered from crime scenes. Initially, gun dealers would receive Demand Letter 2 if they had 10 or more crime guns traced back to them in a calendar year with a “time to crime” of three years or less — a strong indicator of trafficking. But in 2018, the Trump administration raised that threshold to 25 or more crime guns.
Demand Letter 2 served as a notice to gun dealers, and those who received the letter were required to submit limited information about any used firearms they acquired — the gun’s make, model, serial number, and acquisition date — within the past year and for every quarter going forward until instructed otherwise. In this way, the ATF could trace the firearm back to the dealer if it was later recovered by police. As the agency noted, “Without this information, ATF would not be able to link the secondary market firearm to the dealer.”
The ATF used this information to successfully trace over 190,000 firearms between 2000 and 2021. Additionally, the number of crime gun traces completed each year using Demand Letter 2 data increased by a staggering 1,706 percent, rising from 963 traces in 2000 to 17,396 traces in 2021, as shown in the table below. Since 2013, the ATF has traced over 10,000 firearms annually using Demand Letter 2 data.
CRIME GUNS TRACED USING DEMAND LETTER 2 DATA
ATF data also shows that used firearms have a much shorter “time to crime” than new firearms. Between 2017 and 2021, 36 percent of the used firearms that the ATF traced were recovered within one year of being purchased, compared to 24 percent of all new firearm traces. Similarly, 65 percent of all used firearm traces had a “time to crime” of three years or less in that time frame, compared to 44 percent for all other firearms.
a fight for transparency
In announcing the end of the program, the NSSF stated that gun dealers are “the frontline of defense to prevent firearms from being possessed by those who should never have them” while simultaneously lambasting those who attempted to use the list of Demand Letter 2 dealers “to ‘name-and-shame’ firearm retailers for crimes in which they had no involvement.”
The NSSF went so far as accusing former ATF Director Steve Dettelbach of violating the Tiahrt Rider — a congressional budget rider originally drafted by the National Rifle Association that the ATF has interpreted as preventing it from providing certain crime gun tracing information to the public — by sharing the names of Demand Letter 2 recipients in 2022 and 2023 in response to Freedom of Information Act requests. Of course, the ATF did not provide any actual tracing data at the time.
When Brady United analyzed those lists of roughly 1,500 Demand Letter 2 dealers, they found that the ATF had previously cited many of them “for breaking federal firearms laws.”
They also found that some of the country’s largest retailers did not receive Demand Letter 2 during those years because they had implemented business practices designed to prevent straw purchases and gun trafficking, including securing their inventories and training employees to stop suspicious sales.
helping the gun industry
Ending the Demand Letter 2 program is the latest in a series of moves by the Trump administration to reshape the ATF in alignment with firearm industry priorities. Since taking office, the administration has:
- Rescinded the “zero tolerance” policy of revoking the licenses of dealers who willfully violated federal law;
- Announced that the gun dealers who had their licenses revoked under that policy may reapply and issued internal guidance instructing ATF personnel to exercise leniency during inspections;
- Expanded the list of state permits qualifying as “Brady alternatives,” enabling more gun buyers to bypass federal background checks; and
- Made it harder for ATF agents to receive alerts when suspected straw purchasers or gun traffickers attempt to buy firearms from dealers.
What’s next for the ATF remains uncertain. Last month, reports surfaced that Trump administration officials were discussing merging the ATF with the DEA. More recently, the Department of Justice reportedly proposed cutting the ATF’s budget by $417.6 million and eliminating 1,465 positions, including 541 investigators responsible for inspecting gun dealers to ensure they comply with federal gun laws.