I-594 has a number of issues that are not clear. Perhaps the most vague is section 3. (4)(f)(ii) which is an exception to the requirement that background checks need not be done prior to a transfer:
if the temporary transfer occurs, and the firearm is kept at all times, at an established shooting range authorized by the governing body of the jurisdiction in which such range is located;
The question is what does “kept at all times” mean? Does this mean for the duration of the transfer or does it mean the gun stays at the range until the end of time? Well, we might be able to rule out “until the end of time”. But it could easily be interpreted as the gun belongs to the range such as a rental gun.
I think we can get a clue as to what was meant by this by the counter example in section 3. (4)(f)(iii):
if the temporary transfer occurs and the transferee’s possession of the firearm is exclusively at a lawful organized competition involving the use of a firearm,
Notice the different language used. Had they intended for the first exemption to mean “the gun must not leave the range while in use by your friend” or something similar they would (should?) have used language such as:
if the temporary transfer occurs, and the transferee’s possession of the firearm is exclusively at an established shooting range authorized by the governing body of the jurisdiction in which such range is located;
While one could argue that I am giving them too much credit for deliberate and clear use of the language I wonder what the courts will think. And keep in mind this is the age of Gruber and admitted deliberate deception by the authors of the law. The authors of I-594 have close philosophical ties to the authors of Obamacare. I strongly suspect they intended for it to be ambiguous so they could claim one thing before the election and another when it was being enforced.