Yes, and to that end I made the comment relevant to your claim. The commissioner is more accurate if you are moving which means you must be placing much hope on the use at range where it is soundly beaten by, well, lots of stuff.

While the Commissioner has better accuracy while moving, The TRAP trumps it at a medium range, where you have the ability to spread more bullets quicker. Not to mention the larger clip (provided you aren't using triple burst, which isn't the smartest at medium range).

When you can land consecutive shots into the opponent over a larger amount of time compared to your opponent, your victory depends on your opponents accuracy. They'd need to land every single shot to make it count, while you wouldn't need to. Also, the Commissioner could need about three shots to kill someone in their face (might not be accurate, talking simply from experience here) while the TRAP only needs two (in the triple burst mode).

I don't actually think that's true. The Vandal, for example, has .75 ADS, vastly superior hipfire performance, better moving accuracy, more damage in a magazine and a lower TTK in literally any circumstance.

Should you meet a Vandal user in CQC, aiming down sights would make you a slow target, even with .75 ADS. And then, the Vandal user is still reliant on hitting all of their shots, while you can easily spread your bullets around. Also, if I'm not mistaken, the max damage on the TRAP-M1 is per bullet. Meaning you can pump out a whopping 552 damage in a triple-burst. This outclasses the Vandal, with its 334 max damage. Also, the Vandal user would have to be very accurate and land all shots. Meanwhile the TRAP user can spread bullets like mad, if only 6 bullets hit, that could be enough to take down an enemy infiltrator.

I would also like to carry the battle rifle on an infiltrator, but until then, it works amazingly good on engineers in those long ranged Indar fights. In other cases, it's very good on Heavy Assaults, providing the survivability needed for it to work well in a 1v1, while also making good use of it at range. It decimates infiltrators and is very good used otherwise since it has better accuracy and range than an LMG/Carbine/SMG. So I could absolutely recommend trying it out on a Heavy Assault.