Correct, Official rules have not been published per jcar rules and open for public comment. Looks like ISP has gotten way out over their skies by sending this out to dealers ahead of jcar approval.
Are dealers still expected to be certified and compliant this month even though JCAR submission hasnt been done?
Q. When does the new law take effect?
A. The statute was effective January 18, 2019 and requires all affected persons or entities to be certified by July 17, 2019.
Q. Is there a deadline for compliance?
A. All FFLs who wish to continue doing business without interruption must submit their application to the ISP by June 17, 2019. This allows the Illinois State Police time to process the certification prior to the July 18, 2019 deadline. If the Illinois State Police does not issue a certificate by July 18, 2019 and 30 days have passed since your submission, you may continue to operate as if you have been issued a certificate or until the Illinois State Police issues a denial letter.