M855 Ammo Already Banned?

According to Townhall, the BATFE-EIEIO removed the exemption of M855 a month before the comment period was even opened:

A review of the timeline: 
January 2015: ATF published a new, OMB approved Regulation Guide stripping AR-15 "green-tip" from its armor piercing exemption list.
February 2015: ATF proposes a ban (which they've already put in place through their handbook published in January) on AR-15 "green-tip" ammunition and opens up a comment period. 
March 16, 2015: The comment period about the proposed/already implemented ban on AR-15 "green-tip" ammunition closes, ATF ignores tens-of-thousands of comments because they were never going to consider them in the first place, and continues with the regulations outlined in the new 2014 Regulation Guide.

This is not democracy. This isn't even a Representative Republic.  This is ruling by bureaucratic fiat. 

So are all the individuals that bought/sold this ammo after Jan now felons?

The ATF needs to have their funding reduced.

Here's the link to the guide.  Pg 190