This date is the government's estimate of how much time is needed to decide what to do about the proposal: change it, enact it, drop it, etc. Until then, they have 9,000+ comments to review, including Arsenal Attorneys' own comment in opposition to the proposal. If the government decides to enact a proposal, time must then be given to provide the public advance notice to prepare before new rules would take effect.  

So conditions are very much in flux. The proposal could become better or worse, or whither on the vine. What will effect the outcome? The pace of the government, the strength of arguments for/against the rule, politics, and a variety of other known and unknown factors. 

We do want to clear up confusion caused by 41P already. Some mistakenly believed the end of the 90 day comment period was the cut-off date before new rules would take effect. Others believed there was reason to abandon plans to obtain NFA firearms altogether. In fact, even the current form of 41P would allow current trusts and tax stamps to remain valid, and it would allow trusts to register new NFA firearms subject to the proposal's conditions. The fact is, there's never been a more important time to obtain NFA firearms, including silencers, short-barreled rifles and shotguns, and machine guns.

Every day we continue helping clients create Arsenal Gun Trusts to help them transfer and/or build NFA firearms, and our best advice is to take full advantage of current conditions before they might change. 41P is not a 'done deal.'