Notice to S&W M&P 15-22 Rifle Owners

[cybershooters]

I've tried at various times all day to get hold of someone in charge at the CFC without success. The CFO left me a message saying this was the first he'd heard about these letters going out (I have yet to speak to him, I find this a bit hard to believe).

What they fail to grasp is this - they've sent out a letter on RCMP headed paper, with a threat of criminal prosecution within 40 days about a Criminal Code violation - on that basis all the rules of criminal law apply and you have a right to remain silent and not tell them a bloody thing. Also that they're asking for information to support a change to a registry record they're not authorized to maintain in the first place, a detachable magazine is an accessory, it is not a characteristic of a firearm.

Sorry it makes a mess of your bureaucracy but you should have thought about that before you broke the law.

 

[cybershooters]

Mmm, I've just checked through the Act and the regulations again, the CFC is only mandated to maintain records on "cartridge magazines" that are possessed by public agencies, not ordinary licence holders, assuming I've gone through this correctly. The fact that the term "cartridge magazines" is used in the regulations indicates that they are not covered by the definition of a "firearm".

Ergo, the CFC not only cannot lawfully request this information they're not supposed to have it in the first place.

 

[Chuckbuster]

Mmm, I've just checked through the Act and the regulations again, the CFC is only mandated to maintain records on "cartridge magazines" that are possessed by public agencies, not ordinary licence holders, assuming I've gone through this correctly. The fact that the term "cartridge magazines" is used in the regulations indicates that they are not covered by the definition of a "firearm".

Ergo, the CFC not only cannot lawfully request this information they're not supposed to have it in the first place.

That's an interesting point. Also, consider that in order to have North Sylva pin magazines, the number of magazines you are having pinned is required. Does this mean that North Sylva is required to pass on the number of magazines an individual owns to the RCMP? Why do they require information on the number of magazines an individual has? Will RCMP be keeping track of owners' magazines? If so, what about trading/selling magazines? Once pinned (or if you already have 10 rounders), they are no longer prohibited/controlled devices and can be traded or sold freely. What then?

And yes, the more I think about this whole mess, the angrier I become!

 

[tiriaq]

Possession of a prohibited device would be a violation of the law.
The RCMP is demanding evidence that the affected individuals are not in violation of the law.
But the basis for Canadian jurisprudence is that there is a presumption of innocence until guilt is proven.
It is not up to the individual to prove innocence; it is up to the courts to prove guilt beyond a reasonable doubt.
It would seem that there is no legal basis whatsoever to justify the demands being made by this person on behalf of the RCMP.
The RCMP can notify affected citizens that magazines which they may or may not possess are deemed by the RCMP to be prohibited devices.
If the RCMP can make a case before a judge that there is a strong probablity that an individual is in possession of an illegal object, the judge could issue a search warrant.
But if the individual states that he has taken the necessary steps to comply with the law, then that should be the end of the matter, unless there is compelling reason to believe otherwise.
The issue needs to be carefully examined by legal counsel.
There is a strong possibilty that this individual acting on behalf of the RCMP has gone far beyond what would be lawful, and has violated the basic rights of many persons.

 

[JimV]

...There is a strong possibilty that this individual acting on behalf of the RCMP has gone far beyond what would be lawful, and has violated the basic rights of many persons.

The individual in question is Nicole Boucher, Registrar of Firearms, RCMP, CFC.
At least that is who signed the letter I rec'd. She copied the CFO, BC.

 

[tiriaq]

The major organizations have legal counsel, and there are attorneys who are members here. Perhaps this is an issue that would be worth vigorously pursuing. It could be argued that the possession of firearm magazines is not something with which the Registrar of Firearms has any involvement whatsoever. Perhaps this worthy individual has greatly overstepped the limits of her responsibilities.

 

[sw686blue]

So, are there any lawyers on the forum that can provide us with some clear answers??

 

[Questar]

Possession of a prohibited device would be a violation of the law.
The RCMP is demanding evidence that the affected individuals are not in violation of the law.
But the basis for Canadian jurisprudence is that there is a presumption of innocence until guilt is proven.
It is not up to the individual to prove innocence; it is up to the courts to prove guilt beyond a reasonable doubt.
It would seem that there is no legal basis whatsoever to justify the demands being made by this person on behalf of the RCMP.
The RCMP can notify affected citizens that magazines which they may or may not possess are deemed by the RCMP to be prohibited devices.
If the RCMP can make a case before a judge that there is a strong probablity that an individual is in possession of an illegal object, the judge could issue a search warrant.
But if the individual states that he has taken the necessary steps to comply with the law, then that should be the end of the matter, unless there is compelling reason to believe otherwise.
The issue needs to be carefully examined by legal counsel.
There is a strong possibilty that this individual acting on behalf of the RCMP has gone far beyond what would be lawful, and has violated the basic rights of many persons.

What you say sounds good... but now let's look at it from a slightly different standpoint.

• The records that CFC/RCMP have show that person "X" purchased an S&W M&P 15-22 rifle along with a magazine that is currently classified as a Prohibited Device.
• Person "X" was notified directly that they are in possession of said Prohibited Magazine and given several options to avoid being charged.
• Person "X" was asked to show evidence that they have complied with one of those options.
• While the RCMP may not have legal grounds for "forcing" Person "X" to send a copy of the evidence tag showing the magazine was turned into police for destruction, they would have grounds, (based on the previous information and their "belief" that Person "X" still has possession of the Prohibited Magazine) to obtain a warrant to search Person "X's" home, etc. for the Prohibited Magazine or evidence thereof.

So... RCMP come to your door with a warrant and tear your place apart looking for a magazine that may or may not exist... when all you needed to do to avoid that was supply them the evidence tag? Who knows what else the "find" while doing their search?

Personally, I don't need that kind of pointless confrontation... or the damage that would occur during such a "search".

Suit yourself... make a point if you really believe it's necessary... but don't be surprised when the other side makes a "point" right back at you.

It's taken many many months for those "letters" to go out to registered owners... you don't think that the government lawyers/crown attorneys haven't had input on the best way to deal with the situation? Whether to confiscate the magazines or whether to allow a process for owners to "pin" them (a process which is not actually contained in the firearms act as permissable but for which there was legal precedent)? It's been a year since the RCMP SFSS ruled on these magazines but notification of the ruling was held up for months at the adminstrative and justice levels... and then many more months before actual legal notifications were made. They have been very careful to follow a course of action that is both legal and defenceable in court.

Challenge them all you like but be prepared for the consequences. Choose your battles wisely... this is NOT a good one to choose (in my opinion ).

Mark

 

[Utah]

What you say sounds good... but now let's look at it from a slightly different standpoint.

• The records that CFC/RCMP have show that person "X" purchased an S&W M&P 15-22 rifle along with a magazine that is currently classified as a Prohibited Device.
• Person "X" was notified directly that they are in possession of said Prohibited Magazine and given several options to avoid being charged.
• Person "X" was asked to show evidence that they have complied with one of those options.
• While the RCMP may not have legal grounds for "forcing" Person "X" to send a copy of the evidence tag showing the magazine was turned into police for destruction, they would have grounds, (based on the previous information and their "belief" that Person "X" still has possession of the Prohibited Magazine) to obtain a warrant to search Person "X's" home, etc. for the Prohibited Magazine or evidence thereof.

So... RCMP come to your door with a warrant and tear your place apart looking for a magazine that may or may not exist... when all you needed to do to avoid that was supply them the evidence tag? Who knows what else the "find" while doing their search?

Personally, I don't need that kind of pointless confrontation... or the damage that would occur during such a "search".

Suit yourself... make a point if you really believe it's necessary... but don't be surprised when the other side makes a "point" right back at you.

It's taken many many months for those "letters" to go out to registered owners... you don't think that the government lawyers/crown attorneys haven't had input on the best way to deal with the situation? Whether to confiscate the magazines or whether to allow a process for owners to "pin" them (a process which is not actually contained in the firearms act as permissable but for which there was legal precedent)? It's been a year since the RCMP SFSS ruled on these magazines but notification of the ruling was held up for months at the adminstrative and justice levels... and then many more months before actual legal notifications were made. They have been very careful to follow a course of action that is both legal and defenceable in court.

Challenge them all you like but be prepared for the consequences. Choose your battles wisely... this is NOT a good one to choose (in my opinion ).

Mark

Sounds reasonable enough.. I just wonder about those guys who damaged their mags and inadvertantly tossed them in the trash. Not sure they deserve to have their homes turned upside down over a mag that was trashed two years ago.
This appears to be how criminals should be treated.. why not simply ask the citizen? Given that they only "believe" he has the mag - previous owner can set them straight and all done with.

 

[cybershooters]

[*]The records that CFC/RCMP have show that person "X" purchased an S&W M&P 15-22 rifle along with a magazine that is currently classified as a Prohibited Device.

A record they're not authorized to maintain prior to it becoming a prohibited device, therefore they have violated section 4 of the Privacy Act and I seriously doubt a prosecution could be successful in that case.

[*]Person "X" was notified directly that they are in possession of said Prohibited Magazine and given several options to avoid being charged.
[*]Person "X" was asked to show evidence that they have complied with one of those options.

Evidence which in many cases is impossible to provide because it doesn't exist.

[*]While the RCMP may not have legal grounds for "forcing" Person "X" to send a copy of the evidence tag showing the magazine was turned into police for destruction, they would have grounds, (based on the previous information and their "belief" that Person "X" still has possession of the Prohibited Magazine) to obtain a warrant to search Person "X's" home, etc. for the Prohibited Magazine or evidence thereof.
[/LIST]

On what basis? There is no probable cause because the information to support the application for a warrant is illegally maintained, moreover the probable cause would have been obtained by requiring a person to be a witness against themselves, a violation of their civil rights, and using a method that was impossible for the person to comply with.

I'm not worried frankly, I can't see they've got a leg to stand on. As soon as I read that letter and saw they were asking people to do something which in many cases is impossible to do I knew they'd screwed up. Then I spoke to that woman who started yapping on about "verifying" my rifle, which they're not authorized to do I knew for sure they'd screwed up.

I'm from the UK originally and I've received more stupid letters from the police than I can count, I've literally got a drawer full, I know bull#### when I read it and I'm not intimidated.

 

[cybershooters]

It's taken many many months for those "letters" to go out to registered owners... you don't think that the government lawyers/crown attorneys haven't had input on the best way to deal with the situation?

No, I don't think they did, frankly. Any moron can see that you can't provide evidence of the destruction of a magazine.

Since I've lived in Canada I've seen a lot of this "moan about something and then do nothing" attitude, I get the impression Canadians are very stuck in their ways.

Seriously, the whole thing is a farce compared to the UK, I'm not even slightly concerned or intimidated by a "confrontation" with these idiots.

 

[FawkQ]

I just sent an email to my MP in Cold Lake, AB addressing this issue. I think if everyone wrote their local MP then perhaps something can be done about this, so I strongly encourage everyone to do this, and I don't even care if you copy and paste and change the name at the bottem, or add more or whatever... I also "cc'd" the CFC. Strength in numbers people, c'mon.

Good morning MP Sir,

Last week I received a letter in the mail regarding my Smith & Wesson M&P 15-22 Rifle. The letter stated that the magazine sold with my rifle can fit both my rifle and a new pistol that Smith & Wesson released, the Smith & Wesson M&P 15-22P Pistol. The letter then went on to say I have to either:
A) alter my 25 round magazine to 10 round (When I called the firearms office they told me after it has been altered it must be “verified” by someone who is qualified and has taken the verifier course. How much is that costing us?)
B) exchange my 25 round for a 10 round at a business that is licensed to do so, or
C) surrender the 25 round to the police for disposal.

My concern is this:
1) How much is this "situation" costing the tax payer?
2) How much are they willing to spend to pursue this?
3) Do you think that this is the best way to invest tax dollars?
4) Could you provide a reasonable explanation for this situation? Who is this benefiting?
5) Could you provide a copy of the documentation used to justify the "Former prohibited order #9"?

Just to AMPLIFY on how unreasonable this new “regulation” is, once I do alter/exchange/surrender my 25 round magazine, there is NO policy on purchasing a 50 round drum magazine specifically designed for Smith & Wesson M&P 15-22. If this 50 round drum can fit the Smith & Wesson M&P 15-22 (Rifle) then it can obviously fit the Smith & Wesson M&P 15-22P (Pistol), just as the 25 round magazine could fit both firearms, and I can sure you this 50 round drum magazine is very readily available for retail in Canada. So, how do they justify wasting the Canadian tax payers money in pursuing this situation when one could just as easily go purchase a 50 rounder after altering/exchanging/surrendering their 25 round magazine?

Aside from that, I do not own a Smith & Wesson M&P 15-22P Pistol... so how could I fit a magazine into a pistol that I do not own, and have ZERO interest in ever acquiring? Shouldn’t this regulation only apply to those that own the Smith & Wesson M&P 15-22P Pistol?

Also, if this new regulation is a must have, then why are the owners of the Smith & Wesson M&P 15-22 rifle being penalized in paying out of their own pocket to be in compliance of this new regulation? The Canadian Firearms Program introduced this regulation long after the Smith & Wesson M&P 15-22 rifle was marketed, so why should we have to pay for them “making rules up as they go”? Why are we not being reimbursed for them “making rules up as they go”? Why aren’t we being grandfathered and having ”Prohibited” added to our firearms licence since we owned these items BEFORE they introduced this regulation, allowing us to own these magazines legally which would save huge amounts of tax payers money?

Here is a link to a youtube video proving that the 50 round drum can fit a Smith & Wesson M&P 15-22P Pistol: http://www.youtube.com/watch?v=_HkSwTDGD-o

I have also attached a copy of the letter I received, the file is in pdf format.

Surely you can see my concern in this matter.

This issue needs to be addressed ASAP, for obvious reasons.

Please RSVP.

Cheers!
John Rickert
Cold Lake, AB.

 

[Questar]

No, I don't think they did, frankly. Any moron can see that you can't provide evidence of the destruction of a magazine.

Since I've lived in Canada I've seen a lot of this "moan about something and then do nothing" attitude, I get the impression Canadians are very stuck in their ways.

Seriously, the whole thing is a farce compared to the UK, I'm not even slightly concerned or intimidated by a "confrontation" with these idiots.

Always fun to watch how fast some people start using derogatory words or phrases like "any moron can see...". Are you suggesting that I'm a moron because I can't see your point? Why do you feel the need to start using such comments to re-inforce your point... let your point stand for itself.

With respect to your point... I believe the RCMP/CFC letter to people instructed them of the various options available to them... the destruction option was not for a person to destroy it by tossing it in the garbage... it was to turn the item into police for destruction... doing so creates a permanent record and does provide a legal proof that you complied with their demands.

Mark

 

[sewktbk]

Always fun to watch how fast some people start using derogatory words or phrases like "any moron can see...". Are you suggesting that I'm a moron because I can't see your point? Why do you feel the need to start using such comments to re-inforce your point... let your point stand for itself.

With respect to your point... I believe the RCMP/CFC letter to people instructed them of the various options available to them... the destruction option was not for a person to destroy it by tossing it in the garbage... it was to turn the item into police for destruction... doing so creates a permanent record and does provide a legal proof that you complied with their demands.

Mark

OK so...what happens to the ones who really sold the magazine and can't prove it? or had a defective one and threw it in the garbage, before the prohibited status came into effect??

My answer would have been this :

" I don't have it anymore. Either you take my word for it and write it down in your little notes, or you come to my door with a warrant.

Thank you, have a good day."

 

[Questar]

A record they're not authorized to maintain prior to it becoming a prohibited device, therefore they have violated section 4 of the Privacy Act and I seriously doubt a prosecution could be successful in that case.

How do you figure that they are NOT legally allowed to maintain the record of the transfer of the "Restricted Firearm" (S&W M&P 15-22 rifle) to you... isn't that the requirements under the Firearms Act and isn't that their legal responsibility to do just that? The firearm was imported and registered as including a 25 round magazine... is it such a stretch that they reasonably believe that you purchased it from the dealer with that magazine and if the registration of your transfer occurred prior to the RCMP making their ruling public then they can reasonably assume you may be in possession of what you may not know is a Prohibited Device.

Please explain exactly how they have violated section 4 (or any other section) of the Privacy Act as you state above.

Evidence which in many cases is impossible to provide because it doesn't exist.

If people follow one of the options that CFC/RCMP presented in the letters they sent out then "evidence" of compliance would be possible to provide... if you don't follow the options given and decide (or decided) to pursue your own course of action then you may be correct and you may not have any such evidence to provide. Whether it is reasonable for a person to destroy a prohibitied device without any proof or record of that destruction is a whole other topic for discussion... but that was never part of this thread or my posting.

On what basis? There is no probable cause because the information to support the application for a warrant is illegally maintained, moreover the probable cause would have been obtained by requiring a person to be a witness against themselves, a violation of their civil rights, and using a method that was impossible for the person to comply with.

So you say... but not actually true.

I'm not worried frankly, I can't see they've got a leg to stand on. As soon as I read that letter and saw they were asking people to do something which in many cases is impossible to do I knew they'd screwed up. Then I spoke to that woman who started yapping on about "verifying" my rifle, which they're not authorized to do I knew for sure they'd screwed up.

So you've told them to stick it and challenged them to come and take action against you? You will refuse to comply and fight them in court? I can't wait to see the outcome... wish you luck... think you're going to need it.

I'm from the UK originally and I've received more stupid letters from the police than I can count, I've literally got a drawer full, I know bulls**t when I read it and I'm not intimidated.

Well I'm from Canada and I know that when I tell the police to go xyz! themselves they more than often xyz! me... but you're the expert. Hope that works out for you

Mark

 

[cybershooters]

Always fun to watch how fast some people start using derogatory words or phrases like "any moron can see...". Are you suggesting that I'm a moron because I can't see your point? Why do you feel the need to start using such comments to re-inforce your point... let your point stand for itself.

Oh dear, you are very touchy, obviously I meant they were morons. Just because they used a lawyer doesn't mean he knows what he's doing.

 

[Questar]

OK so...what happens to the ones who really sold the magazine and can't prove it? or had a defective one and threw it in the garbage, before the prohibited status came into effect??

My answer would have been this :

" I don't have it anymore. Either you take my word for it and write it down in your little notes, or you come to my door with a warrant.

Thank you, have a good day."

Look... I'm not defending all of this crap... but I am seeing it for what it really is and not for what many people are twisting it to be.

If you destroyed the magazine it was because you knew (read on Gunnutz or heard somewhere else) that the magazine was deemed a Prohibited Device... and if you didn't think ahead and realize that you might need proof of destruction at some point in future, then you deal with it the best you can... you explain the situation and like you said, if they want to come search then their's not much you can do about it now.

If you sold the rifle then likely you never get the letter since the records show you don't own it anymore and the letter likely goes to the next guy who does have it registered in their name.

I keep reading on these forums that the RCMP re-classified the magazine... that's BS... the magazine was always legally a prohibited device but it went un-noticed for a number of month in 2010 because they never actually did a review and determination. It wasn't until the Pistol version of the gun started to arrive in Canada (a few months after the rifle version) that RCMP reviewed the magazine and classified it as a handgun magazine and limited to 10 rounds maximum.

The fact that the pistol version of the gun didn't appear in Canada until some months after the rifle version was never the issue (it isn't)... both guns were planned by S&W right from the start... both guns were designed by S&W from the start and both were promoted in the annual S&W catalogue together and the magazine (25 round magazine) was advertised as being for BOTH and shown pictured in both.

If you want to blame anyone then blame the importers for not realizing that the 25 round M&P 15-22 magazines were in fact dual purpose and legally required to be 10 round capacity regardless of the firearm in which they were used or sold. In fairness to the importers we had no way (at that time) to understand that the magazine regulations would treat what we all thought was a rifle magazine as a dual rifle/handgun magazine and limit its' capacity to 10 rounds maximum. Because of the way the politicians wrote the law this was the ONLY ruling that the RCMP could make that would stand up in court... and that is quite clear now... but it wasn't so clear at that time.

The other thing that is clear is that this magazine ruling became known over a year ago (last summer) when I posted on Gunnutz that we had been informed by RCMP that the 25 round S&W M&P 15-22 magazines were deemed to be Prohibited Devices and only allowed to have a 10 round capacity. I was derided... called names... accused of spreading rumours in an attempt to sell other brands of magazines... all kinds of things. For months afterwards many people continued to sell the rifles with 25 round magazines, putting every buyer into this situation and blaming me for making it difficult for them to unload their inventory or dump their gun.

The RCMP officially posted about the ruling many months ago and now they are sending out letters to registered owners of the firearm... what's the big surprise?

If you bought your gun (and the magazine) since last September then you should be asking yourself why the seller put into your possession a magazine that they were informed was a Prohibitied Device.

Mark

 

[cybershooters]

How do you figure that they are NOT legally allowed to maintain the record of the transfer of the "Restricted Firearm" (S&W M&P 15-22 rifle) to you... isn't that the requirements under the Firearms Act and isn't that their legal responsibility to do just that? The firearm was imported and registered as including a 25 round magazine... is it such a stretch that they reasonably believe that you purchased it from the dealer with that magazine and if the registration of your transfer occurred prior to the RCMP making their ruling public then they can reasonably assume you may be in possession of what you may not know is a Prohibited Device.

The regulations do not permit them to maintain a registry of cartridge magazines. The transfer has nothing to do with it, they are asking us to have the ten-shot capacity of the magazine verified. There is no legal authority to do that. I know you can say that they're trying to do us a favour but I was specifically told they would put down "ten shot capacity" in the registry - there's no legal authority for that I can find.

Please explain exactly how they have violated section 4 (or any other section) of the Privacy Act as you state above.

Public agencies are only allowed to collect information authorized by law. They are not authorized, simple as that.

So you've told them to stick it and challenged them to come and take action against you? You will refuse to comply and fight them in court? I can't wait to see the outcome... wish you luck... think you're going to need it.

I've been compelled to tell them to stick it because I can't prove what they're asking. CPS has a record of it, I have no access to that record because they never answer the phone and they can't be bothered to get it.

Well I'm from Canada and I know that when I tell the police to go xyz! themselves they more than often xyz! me... but you're the expert. Hope that works out for you

I'm not suggesting that you haven't, I'm just saying generally that people do whinge a lot on here then do nothing. I'm not trying to disparage your efforts.

 

[cybershooters]

Look... I'm not defending all of this crap... but I am seeing it for what it really is and not for what many people are twisting it to be.

I appreciate what you're saying, really I do, I'm not suggesting this is a conspiracy against gun owners and yes, North Sylva were the ones who cocked up in the first place.

However I actually have been to court on firearms matters and I have had the police come around with a search warrant, etc. and I can tell the way they are going about this is on questionable legal ground. #####ing and moaning about this sort of thing is second nature to me.

If you don't ##### and moan then it will just keep happening.

 

[JimV]

A careful and cautious analysis, Mark, but I would like to rebut several points:

What you say sounds good... but now let's look at it from a slightly different standpoint.

[*]The records that CFC/RCMP have show that person "X" purchased an S&W M&P 15-22 rifle along with a magazine that is currently classified as a Prohibited Device.

Yes, "X" owns the rifle and, by inference, at least one magazine. This does not, of course, identify anyone who may own a magazine but not the rifle (dealer, gun show trader, etc.)

[*]Person "X" was notified directly that they are in possession of said Prohibited Magazine and given several options to avoid being charged.

The notification part is fine, though long overdue. Posting a notice on the CFC web site, as they did, was an entirely inadequate response. All that half the guys in my club know about the internet is that their kids buy CDs on something called eBay.

[*]Person "X" was asked to show evidence that they have complied with one of those options.

As has been noted before, this is an absurd demand since it is impossible to prove a negative. Many people, including me, had more than one magazine. Establishing that one was pinned or destroyed proves nothing about the others.

[*]While the RCMP may not have legal grounds for "forcing" Person "X" to send a copy of the evidence tag showing the magazine was turned into police for destruction, they would have grounds, (based on the previous information and their "belief" that Person "X" still has possession of the Prohibited Magazine) to obtain a warrant to search Person "X's" home, etc. for the Prohibited Magazine or evidence thereof.
[/LIST]

So... RCMP come to your door with a warrant and tear your place apart looking for a magazine that may or may not exist... when all you needed to do to avoid that was supply them the evidence tag? Who knows what else the "find" while doing their search?

Personally, I don't need that kind of pointless confrontation... or the damage that would occur during such a "search".

Frankly, I find this a rather breathtakingly submissive attitude. You say: A police agency can make an extra-legal, or possibly illegal, demand (and one which can prove nothing, as noted above) and we should comply or expect the door to be broken down at midnight. Last time I looked Canada was not run by jackbooted bureaucrats and we should do nothing to encourage that development.

Suit yourself... make a point if you really believe it's necessary... but don't be surprised when the other side makes a "point" right back at you.

There are several points that can be legitimately and constructively made, regardless of whether an owner sends them the bogus "evidence." To wit:

a) The RCMP should have made the proper classification decision initially. They had an evaluation rifle for months. Do you think it came with a special "Safe for Children" 10 round magazine?
b) Having decided months after sales commenced that the magazine should be prohibited, they should have notified owners immediately so as not to expose them unwittingly to criminal prosecution.
c) That notification, when it did come a year later, should not have included a heavy handed threat to invoke police agencies. We are talking about a government interface with law abiding citizens here, not criminals.
d) Compensation should have been offered, as per the Norinco T97s, for the financial loss of owners/dealers.
e) The process for tracking the disposition of the magazines is obviously deeply flawed. First of all, it is literally impossible to establish a negative and secondly, their own staff have been giving confusing, contradictory and ridiculous instructions to people who call in.
f) The entire issue is fundamentally trivial and involves no public safety dimension. Spending more time and money on it is a waste of public resources.
g) The issue arises from a regulatory framework that is ambiguous, irrational, ineffective and which engenders disrespect for the law.

It's taken many many months for those "letters" to go out to registered owners... you don't think that the government lawyers/crown attorneys haven't had input on the best way to deal with the situation?

We'll never know, but I doubt it. Any attorney would have instantly recognized the absurdity of the process they have developed. I think it was a hastily cobbled together CYA operation set up to avoid closer scrutiny by their political masters who were concerned by complaints about the lack of notification.