As usual with these rule changes, the devil is in the details. From what I have seen it is hundreds to pages and creates a framework where there is a lot of discretion and subjectivity on the part of the ATF to charge people under the rule. There is no bright-line rule with regard to the number or frequency of transfers. It gives feds too broad of discretion to selectively apply criminal law. If you don’t believe me, look how ATF and DOJ have handled literally every other firearms related issue under this administration.