Hello everyone,

Hopefully some here can steer me in the right direction with this issue. I'm currently stationed in Florida, but moving to Texas in less than 5 weeks. Somewhat short notice. As of right now I do not have an address in TX. I understand the need to file the 5320.20 (seems that I may be able to get one back before I leave Florida based on current turnaround times but don't know for sure). So, I was hoping to convert the rifles to Title I firearms, complete the move, then file the 5320.20 from my new address. Once approved, reassemble and all is well and legal.

Relevant to the discussion are the following rifles:
11.5" AR SBR
16" rifle
CZ Scorpion SBR

My plan is to build a pistol lower and place the 11.5" upper there. I would then place the 16" upper on the SBR lower. Would leave me one "spare" complete lower (among other stripped lowers) for the move. As for the Scorpion, I would simply remove the stock, send it to a family member with no scorpion, and complete the move in pistol configuration.

Just looking for a sanity check here, particularly with the timeline of filing the forms after the move given the configurations I plan to move in. Thanks for any and all help!

Rather than swapping around parts and mailing off stocks, since you have enough time to get an approved form in the 5 weeks, I would do this:

-File a "temporary" 5320.20 now for a generic address in TX, say some gun range near your path of travel.  Date it to be good from today until the end of the year.  This will give you permission to take the NFA items into TX.  email it to the ATF to hasten turnaround, should take 3-4 weeks.

-Once you move and have your address, file another 5320.20, this time as a "permanent" move to your address in TX, thus keeping the ATFs records up to date.

Ah excellent, didn't think about doing it that way. Thanks!

The address you use for your .20 is the arms room or headquarters of your new unit.  They'll always know how to find you.  Five weeks is a long time to get a 5320.20 approved.

I've been on the road between duty stations and my examiner called me while I was west-bound on the interstate to let me know it was approved and was both faxing and mailing copies to my new duty station.

Good idea. Thanks!

I literally just went through this.  After repeated attempts to contact Terry Whitting and hearing nothing back, I was finally recommended to contact Ted Clutter.  I did and was then put in touch with Joyce Leonard.  She approved my 5320.20 within 30 minutes and e-mailed the approved copy to me while sending my paper copy to a forwarding address for me.  That may be a way to go.  As for the address, I used my new unit to which I was reporting and they were cool with that.  If I were you I would just start with Ted and work from there.  He's extremely swamped, but if you follow up a few days later you will get a response.  Good luck!

I'm going to jump in here with a question of my own. Was your permanent residence established in Florida for your home of record? I'm looking to begin building my SBR collection but I get out and move around the November timeframe. Is it difficult to go about getting all of the requirements met while living in a state outside of your permanent residence?

Obviously I can only speak for myself, but my HOR is Fl.  I bought my first can from a Fl dealer while I was living in England.  It wasn't approved until after I moved back to NC.  Another person on my trust picked it up and mailed it to me.  I then got a few SBRs and other cans all while living in NC.  Now that I'm back in Fl I haven't done anything.  My trust has no address on it, is valid wherever I move (as long as the state allows Class 3) and my trust can buy in any state in which a 'responsible party' lives.  So long story longer, I have had no issues using the trust outside of my HOR.  That being said that since HOR and  residence (as far as where you reside physically, not hold your state residency) are 2 completely different things it shouldn't matter.  To buy a can or SBR in NC I only had to show my mil ID and my orders stationing me in NC and I was good.  Just like buying any other gun.  

Hopefully that helps.

The Dude Abides

I appreciate the follow up and insight. I guess the next question is whether or not it's worth it for me to go through the process of setting up a trust? At least starting off, it doesn't seem to be worth the time for me if what everyone has said holds true

Sorry I haven't checked this thread in a few days. HOR is Utah, I owned a suppressor on a trust prior to joining. Got stationed in FL and submitted two sbrs. Trust made it easier as I didn't have to get a Cleo approval or anything, just efiled with the trust I had before. My brothers are on it with me, so if I ever get stationed somewhere unfriendly I transfer the items to them and I'm good for a few years. YMMV

Hopefully you're still following this thread... I assume you used the unit address as a temporary address, then filed a permanent one at your new residence? Thanks for the help, I reached out to Ted today.

In block 7 I just put my new unit's street address.  I didn't put anything about temporary or permanent.  I even asked what to do and was just told to submit it for approval with that address... so I did and viola.  

I haven't updated yet as I'm still in TLF.  The way I understand it is that you only need to report state to state moves, if the item moves around in the state it doesn't matter.  Updating to my permanent address is something I'll do once I'm moved in, but if it follows the same flow as my suppressor 5320.20, there will be no response as it is informational only and does not require approval.  According to Joyce, all the update for suppressors or a different in-state address does is allow the ATF to approve your next 5320.20 quicker since they have an entire history of the locations.  

Hopefully that answers your questions.  Let me know if you have any more.

I appreciate it!