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Yeah, I guess my second paragraph makes it sound like I was referring to the individual applicant. My bad.
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Once you receive an approval under the new rules, you’ll be exempted from having to submit fingerprint cards or passport photos again for 2 years from the date of the most recent approval. (We’re still digging into how, exactly, this will be implemented.)
That's not what the actual 41F says. That's what everybody has repeated because a couple people read it that way...but it doesn't say that. The 24 month window refers to the trust/corp documentation only.
Yeah, I guess my second paragraph makes it sound like I was referring to the individual applicant. My bad.
I'm not sure you actually caught the point I was trying to make.
As I read it, there is no 24-month window for
any applicant, whether individual/trust/corp, as far as photos and prints go. The 24-month window only pertains to providing a copy go the trust, articles of incorporation, etc...whatever "documentation" you're providing to establish the entity's validity.
Regardless of who's submitting, or if you had prior approvals, prints and a <1 year photo will have to be submitted. I don't like it, but that's how I see it written.