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That's the problem with trusts worded this way, and why I specifically purchased a trust that doesn't have a Schedule A. The Form 1/4 is what registers the NFA item to the trust.
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My trust does not have a Schedule A either. Any firearm, NFA or otherwise, that is purchased
by the Trust belongs to the Trust but doesn't get added to the Trust paperwork in any way. Just an accounting/recordkeeping function by the Trustees.
The "issue", if it really is one, is that the non-NFA AR-15 receiver that is to be used by the Trust to make the SBR was initially sold to an individual (before the Trust existed) who is now a Trustee. In order for the Trust to make an SBR out of it, the Trust has to become the owner of it. In most States, no biggie, just a private transfer from individual to Trust and make note of it.
However, if a State says that all transfers have to be handled by a dealer and a background check has to be made...what then? The Trust cannot have a NICS check run against it. In the normal course of things, a Trustee would fill out the 4473 and get a NICS check as the "responsible party". But that party is ALSO me. So me individual to me Trustee. See where this is confusing?
But my current understanding (after conversation with the firm that created my Trust) is that my transfer from Me As Individual to Me As Trustee is exempt under State law.
Clear as mud, right?
Rob