41p Finalized

[BadKarmaZeroSix]

I can't find it right now, but in reference to how things change for a trust, is it a separate set of fingerprints and photos now with each NFA purchase, or kept on file as "this is the guy attached to the trust used"...i have tried reading the rule, but cant find it...
Oh, and minor follow-up question, HOW do we notify the CLEO of purchase? Do we just call and say "hey, i bought a suppressor" or is there a form i send? Do we know this yet?

[plant.one]

I can't find it right now, but in reference to how things change for a trust, is it a separate set of fingerprints and photos now with each NFA purchase, or kept on file as "this is the guy attached to the trust used"...i have tried reading the rule, but cant find it...
Oh, and minor follow-up question, HOW do we notify the CLEO of purchase? Do we just call and say "hey, i bought a suppressor" or is there a form i send? Do we know this yet?

from what i can read its prints and a current (less than 1 yr old) photo of the persons in the trust who can access the NFA items. if you have an approve NFA item in the last 24 months that a set of prints/photos were submitted for, you can claim a waiver - as long as no new people have been added to the trust who are deemed 'responsible parties' or whatever.

i have yet to sort out the how on the CLEO notification. i'm sure there's going to be some kind of form for it though. which appears to mean for a trust that has members who live in multiple jurisdictions that multiple CLEO's will receive the notification. for my trust, the other trustee's live in different city's, and in one case another county.


i have yet to call my CLEO office to find out how much fingerprinting costs. last i checked passport photo's are around $7. so at the very least my cost to file for any NFA item has gone up at least $20, if not more based on when the new rule takes effect - not counting gas/time wasted to get finger printed and photographed. i dont get it - my drivers liscence photo is good for at least 4 years. my passport photo in my passport is good for 10. my fingerprints arent changing anytime soon (or in the past).


all the responsible members of my trust are listed on the schedule A, including their Drivers Liscence numbers and the last 4 digits of their SSN's. i still fail to understand how finger prints and a photo are going to prevent a mis identification of those persons.

[Sithlord]

I can't find it right now, but in reference to how things change for a trust, is it a separate set of fingerprints and photos now with each NFA purchase, or kept on file as "this is the guy attached to the trust used"...i have tried reading the rule, but cant find it...
Oh, and minor follow-up question, HOW do we notify the CLEO of purchase? Do we just call and say "hey, i bought a suppressor" or is there a form i send? Do we know this yet?

from what i can read its prints and a current (less than 1 yr old) photo of the persons in the trust who can access the NFA items. if you have an approve NFA item in the last 24 months that a set of prints/photos were submitted for, you can claim a waiver - as long as no new people have been added to the trust who are deemed 'responsible parties' or whatever.

i have yet to sort out the how on the CLEO notification. i'm sure there's going to be some kind of form for it though. which appears to mean for a trust that has members who live in multiple jurisdictions that multiple CLEO's will receive the notification. for my trust, the other trustee's live in different city's, and in one case another county.


i have yet to call my CLEO office to find out how much fingerprinting costs. last i checked passport photo's are around $7. so at the very least my cost to file for any NFA item has gone up at least $20, if not more based on when the new rule takes effect - not counting gas/time wasted to get finger printed and photographed. i dont get it - my drivers liscence photo is good for at least 4 years. my passport photo in my passport is good for 10. my fingerprints arent changing anytime soon (or in the past).


all the responsible members of my trust are listed on the schedule A, including their Drivers Liscence numbers and the last 4 digits of their SSN's. i still fail to understand how finger prints and a photo are going to prevent a mis identification of those persons.

The new form is referenced as '5320.23'. I don't think it exists yet, as 41F states that it has to go to OMB for approval (Page 232 of the ruling).

As far as fingerprints, it is up to the fingerprint station to set a cost. The ATF estimates, on page 218, that it will take an addition 2 hours PER RESPONSIBLE PERSON to procure photographs (50 minutes) and fingerprints (60 minutes) and complete 5320.23 (15 minutes).

They also estimate that the direct cost burden (page 219) will be $11.32 per photograph and 18.84 per fingerprint set, and about $2 to document the trust and mail it off (to CLEO).

The ATF's claim is that by submitting fingerprints, they can have fewer false positives and false negatives (that is, catching more people that should not be allowed possession, and not accidentally prohibiting an allowed possesser).

In the past, when I have picked up my Form 4 item, I have filled out a 4473, and, I believe, had a background check performed. This would seem useless now, as the ATF knows that the item is no longer in the FFL's inventory, knows EXACTLY where the item is and who it belongs to (defacto registration), and has ALREADY performed a background check on all individuals that can add items to the trust, which is the set of responsible persons.

[dellet]

In the past, when I have picked up my Form 4 item, I have filled out a 4473, and, I believe, had a background check performed. This would seem useless now, as the ATF knows that the item is no longer in the FFL's inventory, knows EXACTLY where the item is and who it belongs to (defacto registration), and has ALREADY performed a background check on all individuals that can add items to the trust, which is the set of responsible persons.

The 4473 has always been useless on NFA items as far as background checks go. It does offer some protection for the dealer as far as confirming that who is picking up the item, is the same as who was approved on the stamp. What may happen is what my dealer already does in the case of a trust. He asks me to sign a statement declaring I am the trust. There may become an official form for this.

It is like trying to cash a check with a business/fictitious name. If you have a declaration from your bank officially identifying you as "monkey business" then you can sign the check and cash it at the issuing bank.

I have no problem with a seller protecting his investment in his business by identifying who he is handing an NFA item to.

[plant.one]

In the past, when I have picked up my Form 4 item, I have filled out a 4473, and, I believe, had a background check performed. This would seem useless now, as the ATF knows that the item is no longer in the FFL's inventory, knows EXACTLY where the item is and who it belongs to (defacto registration), and has ALREADY performed a background check on all individuals that can add items to the trust, which is the set of responsible persons.

The 4473 has always been useless on NFA items as far as background checks go. It does offer some protection for the dealer as far as confirming that who is picking up the item, is the same as who was approved on the stamp. What may happen is what my dealer already does in the case of a trust. He asks me to sign a statement declaring I am the trust. There may become an official form for this.

It is like trying to cash a check with a business/fictitious name. If you have a declaration from your bank officially identifying you as "monkey business" then you can sign the check and cash it at the issuing bank.

I have no problem with a seller protecting his investment in his business by identifying who he is handing an NFA item to.

when i picked up my form4 can from the FFL who did my transfer, if i remember correctly he had me fill out a 4473 but i forget if he actually called it in, or just accepted my CPL in lieu of the actual check.

[Sithlord]

when i picked up my form4 can from the FFL who did my transfer, if i remember correctly he had me fill out a 4473 but i forget if he actually called it in, or just accepted my CPL in lieu of the actual check.

In Michigan, the CCW/CPL suffices for an alternate NICS background check.

https://www.atf.gov/rules-and-regulatio ... rmit-chart