Trust transfers now need box #15 filled out on F4's(WTF update bottom 2)

[ARCHIVED THREAD] - Trust transfers now need box #15 filled out on F4's(WTF update bottom 2) (Page 1 of 2)

Posted: 11/12/2010 9:08:21 AM EDT

I love the ATF. I have gotten 7 transfers to my trust, none of them have anything filled out on the back of the form. Its a trust. There shouldn't be anything filled out. So the latest one I had that got disapproved, the one I had the thread on for the "zombie" reason for owning it. Refilled out the forms, sent them back last week. Get them back today. Section #15 needs to be filled out. The fuck?

I've gotten three transfers from Suzanne in the last two months, all of them done with nothing on the back side of the form. What changed in the last month that now section #15 now has to be filled out???

This is what pisses me off about the ATF. Changing the rules as they see fit.

So are my other 7 forms now not complete? Do they need to be resubmitted with section #15 filled out?

Posted: 11/12/2010 9:21:20 AM EDT

[#1]

Whats on #15?

Posted: 11/12/2010 9:29:26 AM EDT

[#2]

isn't she one of the newer examiners? n00b mistake?

Posted: 11/12/2010 9:45:38 AM EDT

[#3]

I called ATF before I sent mine in for a trust in June and they told me to fill it out. Even though my dealer said not to ATF told me to, so I did. I guess its a new thing.

Posted: 11/12/2010 9:52:19 AM EDT

[#4]

What if we use an LLC?

Posted: 11/12/2010 10:03:53 AM EDT

[#5]

Quoted:
Whats on #15?

#15 is transferee's certification. It shouldn't be filled out for trusts, or for LLC's. I guess next they will ask for a photo to be put on there. You know. Cause it asks for it.

Posted: 11/12/2010 10:04:11 AM EDT

[#6]

Quoted:
What if we use an LLC?

I'd guess you would need it filled out for an LLC as well.

Posted: 11/12/2010 10:07:41 AM EDT

[#7]

I called and spoke with Ted Clutter, who is her supervisor. He advised me that it is not needed to be filled out for a trust, but if she wants it filled out, I should just fill it out to smooth things over and get my transfer approved in a timely fashion. Sounds like one hell of a cop out too me. I know she is doing something wrong, but don't rock the boat, just be a good little subject and make her random wishes come true. He said maybe it was because I had a new examiner, I told him I had one approved on Oct 1st, from her, with nothing on the back. He goes "oh, you are really shooting me down here, you shouldn't have any reason to not fill it out, so just go ahead and do it."

Thanks. So if she wanted, she could ask to have my local CLEO sign off on it, stating that there is nothing in his area that would keep my trust from owning it? Hell, lets finger print every member of the trust as well. Cover all our bases. I asked him if I should have all seven people in my trust sign it, seeing as they want someone to sign. He said no, just me.

Posted: 11/12/2010 11:46:35 AM EDT

[#8]

Quoted:

I called and spoke with Ted Clutter, who is her supervisor. He advised me that it is not needed to be filled out for a trust, but if she wants it filled out, I should just fill it out to smooth things over and get my transfer approved in a timely fashion. Sounds like one hell of a cop out too me. I know she is doing something wrong, but don't rock the boat, just be a good little subject and make her random wishes come true. He said maybe it was because I had a new examiner, I told him I had one approved on Oct 1st, from her, with nothing on the back. He goes "oh, you are really shooting me down here, you shouldn't have any reason to not fill it out, so just go ahead and do it."

Thanks. So if she wanted, she could ask to have my local CLEO sign off on it, stating that there is nothing in his area that would keep my trust from owning it? Hell, lets finger print every member of the trust as well. Cover all our bases. I asked him if I should have all seven people in my trust sign it, seeing as they want someone to sign. He said no, just me.

That's some Grade A retard right there. Hope that gets worked out for you. I'm sending in my first stuff on my trust here soon. Let me know how it turns out.

Posted: 11/12/2010 12:41:33 PM EDT

[#9]

She has nice hand writting.

Maybe they are getting to know you and are trying to slow your form 4s down? You are dealing with the government, after all.

Posted: 11/12/2010 12:50:29 PM EDT

[#10]

FWIW, I have always filled out Question 15 for my transfers to a corporation, going back more than a decade.

My general approach when flling out federal paperwork is, if it doesn't add any time or effort, go for it. The alternative is potential bouncing, and I hate the delays and hassles.

Posted: 11/12/2010 2:06:18 PM EDT

[#11]

Quoted:
FWIW, I have always filled out Question 15 for my transfers to a corporation, going back more than a decade.

My general approach when flling out federal paperwork is, if it doesn't add any time or effort, go for it. The alternative is potential bouncing, and I hate the delays and hassles.

This.

Posted: 11/12/2010 2:54:48 PM EDT

[#12]

Quoted:
She has nice hand writting.

Maybe they are getting to know you and are trying to slow your form 4s down? You are dealing with the government, after all.

That's the thing. Shippman was doing my forms from the dealer I was using before. Always ran around 5 months, with some going upwards of 9 months. With this chick, they have been taking around a month, if not under to get approved. So its not that.

Posted: 11/12/2010 2:58:56 PM EDT

[#13]

Quoted:
FWIW, I have always filled out Question 15 for my transfers to a corporation, going back more than a decade.

My general approach when flling out federal paperwork is, if it doesn't add any time or effort, go for it. The alternative is potential bouncing, and I hate the delays and hassles.

Did you read my update from Clutter? I don't know about you, but I have a problem with that. So the supervisor admits that she is wrong, but doesn't want to get off his ass and fix the problem? Just go ahead and smooth it over, be a good subject, and fill it out to make her happy? If it doesn't need to be filled out, then why is she asking to have it filled out? Its a slippery slope, and I could see them saying, oh, well, its ok to ask for that part to be filled out, how about getting a CLEO to sign off too? Heck, its still in their area, why shouldn't the CLEO sign off saying that there isn't any reason the item can't be owned in his area???

Posted: 11/12/2010 3:42:55 PM EDT

[#14]

great

i have both a form 1 and a form 4 on a trust pending .... hope they don't get bounced

Posted: 11/12/2010 3:45:39 PM EDT

[#15]

I found the verbiage of item 15 to be interesting. Would an individual (side stepping the business entities are generally excluded as OP says) have to fill it for an AOW? No mention of them in the text.

possess the machinegun, short-barreled rifle, short-barreled shotgun, or destructive device described on this application for the following reason(s)

Posted: 11/12/2010 4:58:24 PM EDT

[#16]

The Instructions on the Form 4 for Box 15 - Transferees Certification state the following:

2d. Transferee Certification. Item 15 must be completed by the transferee if:
(1) the firearm to be transferred is a machinegun, short-barreled rifle, short-barreled shotgun, or destructive device;
(2) the transferor is licensed under the GCA to deal in such device or firearm; and
(3) the transferee is not licensed under the GCA to deal in such device or firearm.

When the transferee is not licensed to deal in NFA firearms, that section needs to be filled out regardless of whether it is an individual, Trust, LLC, Corp, etc...

In answer to the question above, that section does not need to be filled out for AOWs or Silencers.

Dan.

Posted: 11/12/2010 5:50:41 PM EDT

[#17]

My dealer filled out my trust info in #15 and I signed it as Grantor and Trustee.

Posted: 11/12/2010 6:11:10 PM EDT

[#18]

Quoted:
The Instructions on the Form 4 for Box 15 - Transferees Certification state the following:

2d. Transferee Certification. Item 15 must be completed by the transferee if:
(1) the firearm to be transferred is a machinegun, short-barreled rifle, short-barreled shotgun, or destructive device;
(2) the transferor is licensed under the GCA to deal in such device or firearm; and
(3) the transferee is not licensed under the GCA to deal in such device or firearm.

When the transferee is not licensed to deal in NFA firearms, that section needs to be filled out regardless of whether it is an individual, Trust, LLC, Corp, etc...

In answer to the question above, that section does not need to be filled out for AOWs or Silencers.

Dan.

So why do I have seven forms approved with it out being filled in, and why does the supervisor say that it doesn't have to be filled in? Is the ATF NFA branch that backwards that they don't have any sort of standard to go by? I mean, I understand that the .gov is not known to have any sort of consistency, but this is a new level of retarded.

Posted: 11/12/2010 6:30:41 PM EDT

[#19]

I've always filled mine out with the trust name and signed it.

Posted: 11/12/2010 6:39:03 PM EDT

[#20]

Quoted:
My dealer filled out my trust info in #15 and I signed it as Grantor and Trustee.

Exactly how mine was done.

ETA: This is from Princelaw.com who specialize in NFA Trusts

Posted: 11/12/2010 6:54:06 PM EDT

[#21]

Quoted:
FWIW, I have always filled out Question 15 for my transfers to a corporation, going back more than a decade.

My general approach when flling out federal paperwork is, if it doesn't add any time or effort, go for it. The alternative is potential bouncing, and I hate the delays and hassles.

Just asking, but do you your SSN on a 4473 as well?

Posted: 11/13/2010 2:51:22 AM EDT

[#22]

Quoted:

Quoted:
The Instructions on the Form 4 for Box 15 - Transferees Certification state the following:

2d. Transferee Certification. Item 15 must be completed by the transferee if:
(1) the firearm to be transferred is a machinegun, short-barreled rifle, short-barreled shotgun, or destructive device;
(2) the transferor is licensed under the GCA to deal in such device or firearm; and
(3) the transferee is not licensed under the GCA to deal in such device or firearm.

When the transferee is not licensed to deal in NFA firearms, that section needs to be filled out regardless of whether it is an individual, Trust, LLC, Corp, etc...

In answer to the question above, that section does not need to be filled out for AOWs or Silencers.

Dan.

So why do I have seven forms approved with it out being filled in, and why does the supervisor say that it doesn't have to be filled in? Is the ATF NFA branch that backwards that they don't have any sort of standard to go by? I mean, I understand that the .gov is not known to have any sort of consistency, but this is a new level of retarded.

I wish I could help there! My suggestion would be to elevate it to the Branch Chief level so that the inconsistencies can get addressed branch wide.

If you want to get even more frustrated, sections 13 & 14, the questions at the top, also need to be filled out for any non-licensee regardless of the type of entity.

Dan.

Posted: 11/13/2010 3:21:14 AM EDT

[#23]

well if its a form4 cant you just put your trust name/info in 15 so it dosent slow anything down? or does it have to be your info? I thought the point of the trust is that its registered to the trust and the list of trustees can have it?

I've never done a trust, never had to. until the sheriff refuses to sign I will save the $300 and extra bs.

Posted: 11/13/2010 3:43:08 AM EDT

[#24]

Quoted:
well if its a form4 cant you just put your trust name/info in 15 so it dosent slow anything down? or does it have to be your info? I thought the point of the trust is that its registered to the trust and the list of trustees can have it?

I've never done a trust, never had to. until the sheriff refuses to sign I will save the $300 and extra bs.

There is no "extra bs". I can have all of my paperwork printed, filled out and in the mail to the NFA branch in less than 30 minutes. You can't get anywhere near that time frame going the individual route.

When I had to do fingerprints for my CWP it took two days to get them done.

Posted: 11/13/2010 5:01:39 AM EDT

[#25]

This could be only the beginning of NFA Branch's incremental approach to making transfers to legal entities (trusts, corporations, partnerships, etc.) more onerous

Posted: 11/13/2010 9:10:15 AM EDT

[#26]

Quoted:
This could be only the beginning of NFA Branch's incremental approach to making transfers to legal entities (trusts, corporations, partnerships, etc.) more onerous

This is what I'm worried about, and kind of annoyed that the supervisor doesn't want to correct the examiner. This is how bad habits start, and once you get a bad habit rolling, then it becomes a rule. Then other rules are started. Then we will have to file a photo and finger print cards for every member of the trust or LLC.

Posted: 11/13/2010 9:43:46 AM EDT

[#27]

I have always filled that section out, used the trust name and signed it grantor and trustee.

My advice(worth what you paid) fill it out and move on with life. Do not "elevate" anything to the branch officer chief or whoever else in the ATF. That's how shit really gets fubar'ed and they start making new rules etc, etc, etc. Just put your trust name in there, sign it and move on.

On a form 1 you fill out 4i and sign section 9 right? I do and always have. On a form 4 it's section 15, you are basically signing the form certifying the same thing.

Posted: 11/13/2010 11:14:42 AM EDT

[#28]

Just looked at my form 4's my dealer has always filled it out but ive never signed any of it. He just put the name of my trust and the date with no signature.

Posted: 11/13/2010 12:26:22 PM EDT

[#29]

Quoted:

Quoted:

This could be only the beginning of NFA Branch's incremental approach to making transfers to legal entities (trusts, corporations, partnerships, etc.) more onerous

This is what I'm worried about, and kind of annoyed that the supervisor doesn't want to correct the examiner. This is how bad habits start, and once you get a bad habit rolling, then it becomes a rule. Then other rules are started. Then we will have to file a photo and finger print cards for every member of the trust or LLC.

I've often warned folks on here that NFA Branch may eventually clamp down and impose tighter restrictions due to the recent proliferation of legal entities (e.g. trusts) as vehicles of transfer for NFA items to 'circumvent' the CLEO signature requirement for individual transfers. I realize the NFA of 1934 specifically enumerates a trust as a proper legal entity, but IMHO, trusts were pretty much off ATF's radar until the internet (and its inherent ease with which to acquire and share knowledge) led to their widespread use; ATF may not be able to easily change existing law, but they can (and do) impose their own requirements in interpreting and administering it.

If you search the archives, then you will find RenegadeX and Tony_K (and maybe jbntex) have echoed likewise sentiments on here as well...

Posted: 11/13/2010 1:06:25 PM EDT

[#30]

Quoted:

Quoted:
FWIW, I have always filled out Question 15 for my transfers to a corporation, going back more than a decade.

My general approach when flling out federal paperwork is, if it doesn't add any time or effort, go for it. The alternative is potential bouncing, and I hate the delays and hassles.

Just asking, but do you your SSN on a 4473 as well?

No, I don't put my SSN on my 4473. It's not required. I was buying a can from an instate dealer (as a trust) and he long drive away. I asked him if he could initiate a form 4 without me being in his shop and I would only have to make the drive to pick it up. You would have though I was asking to sleep with his daughter. Decided to use a different dealer but he recommended I sign #15. He said he had had them kicked back before and it was up to me but to MAKE the ATF happy, I should sign. Of course this is the same guy that insisted that I include a citizen ship cert with my trust.

So I vote that we don't do things just to make ATF happy if they are not required cause of the slippery slop theory...but I find my self doing it cause I'm old and to old to fight the system.

And with that said, remember NFA34 was supposed to make it a pain in the ass to own Title II stuff. So it's working

Just Sayin!

Posted: 11/13/2010 1:14:19 PM EDT

[#31]

Quoted:
I was buying a can from an instate dealer (as a trust) and he long drive away. I asked him if he could initiate a form 4 without me being in his shop and I would only have to make the drive to pick it up. You would have though I was asking to sleep with his daughter.

My old SOT was a 3 hour drive. He filled out the form 4, mailed it to me, then I did my thing. 4473 was filled out when I picked up the item in person.

Posted: 11/13/2010 1:51:26 PM EDT

[#32]

Quoted:

Quoted:
FWIW, I have always filled out Question 15 for my transfers to a corporation, going back more than a decade.

My general approach when flling out federal paperwork is, if it doesn't add any time or effort, go for it. The alternative is potential bouncing, and I hate the delays and hassles.

Just asking, but do you your SSN on a 4473 as well?

No, I don't put my SSN on my 4473. It's not required. I was buying a can from an instate dealer (as a trust) and he long drive away. I asked him if he could initiate a form 4 without me being in his shop and I would only have to make the drive to pick it up. You would have though I was asking to sleep with his daughter. Decided to use a different dealer but he recommended I sign #15. He said he had had them kicked back before and it was up to me but to MAKE the ATF happy, I should sign. Of course this is the same guy that insisted that I include a citizen ship cert with my trust.

So I vote that we don't do things just to make ATF happy if they are not required cause of the slippery slop theory...but I find my self doing it cause I'm old and to old to fight the system.

And with that said, remember NFA34 was supposed to make it a pain in the ass to own Title II stuff. So it's working

Just Sayin!

You have to send the cert of citizenship in for trusts. I've never had a dealer tell me otherwise.

And just to be clear, if #15 has always had to have been filled out, I wouldn't have a problem. My problem is that I've had transfers done by the same examiner with in the last month approved with nothing in #15, and that the supervisor said that it doesn't have to be filled in, but to just do it to make her happy. That is what I have a problem with.

Posted: 11/13/2010 7:13:43 PM EDT

[#33]

Quoted:
And just to be clear, if #15 has always had to have been filled out, I wouldn't have a problem. My problem is that I've had transfers done by the same examiner with in the last month approved with nothing in #15, and that the supervisor said that it doesn't have to be filled in, but to just do it to make her happy. That is what I have a problem with.

Well, that's where we have a different interpretation.

My own take –– and echoed by a former NFA Branch examiner –– is that #15 has always been neccessary for MGs, SBRs, SBS's, etc., though not for suppressors or AOWs.

Yes, you apparently have had some forms approved –– by a newbie examiner –– without #15 being filled out. My own take is that that was done in error. No, you don't need to correct/resubmit them (at least IMHO), but don't complain when a mistake is made in your favor. IMHO.

As far as Ted Clutter's comments via phone ... well, my longstanding opinion is that facts stated in phone conversations with BATFE are worth the paper they are written on. In other words, they are worthless, and may be due to either a miscommunication or a mental burp. Both of which I have had, repeatedly, in my life, so I am not criticising either you or Ted.

I do not see this as a change in ATF policy, because it is compliant with what I have understood to be policy which has existed for decades. Then again, maybe I've been wrong all these years, and there is some sinister manipulation going on.

Y'all are free to make your own call on this. But it does not bother me, and I'm a believer in the motto: Just because I'm paranoid doesn't mean ATF is not out to get me.

YMMV.

Posted: 11/13/2010 7:25:33 PM EDT

[#34]

I have always filled out section 15 and use a Trust.

Posted: 11/14/2010 6:32:31 AM EDT

[#35]

Quoted:
I have always filled out section 15 and use a Trust.

ditto. i just looked at my stamps to see what field that is. and it's filled out and i've signed it every time.

Posted: 11/14/2010 7:41:07 AM EDT

[#36]

Quoted:

Quoted:
I have always filled out section 15 and use a Trust.

ditto. i just looked at my stamps to see what field that is. and it's filled out and i've signed it every time.

I do the same thing.

Posted: 11/14/2010 7:55:12 AM EDT

[#37]

Quoted:
And just to be clear, if #15 has always had to have been filled out, I wouldn't have a problem. My problem is that I've had transfers done by the same examiner with in the last month approved with nothing in #15, and that the supervisor said that it doesn't have to be filled in, but to just do it to make her happy. That is what I have a problem with.

Either you've been slipping in under the radar all of this time or your examiner learned something new in last month's focus group. Either way, you now know what you need to do to get it through without being bounced back. If it gets to be too much, you can always give up stamp collecting. Not trying to start any shit with you, just saying they are not going to continue to make it easy for any of us until some things get changed in DC. With our sub-culture shit always rolls downhill and we're at the base of the heap.

Posted: 11/14/2010 8:03:35 AM EDT

[#38]

damcy62 said "You have to send the cert of citizenship in for trusts. I've never had a dealer tell me otherwise."

I'm just citing...

From the November 2008 FFL newsletter.

The Articles of Incorporation or other documentation establishing the legal entity must be included with the Form 4 application. The documentation must identify a point of contact for the corporation or other entity and must be sufficient for ATF to establish the legitimacy of the existence of the corporation or other entity.

If the firearm being transferred is a machinegun, short-barreled rifle, short-barreled shotgun, or destructive device, an officer or director of the corporation or other entity must complete item 15 on the reverse side of the Form 4.

Items 13, 14, 16, and 17 of the Form 4 do not require completion for a transfer to a corporation or other entity nor is the submission of ATF F 5330.20, Certification of Compliance with 18 U.S.C. 922(g)(5)(B), required.

So, I'm guessing that martinsburg is just ignoring this or it has already been rescinded as so much other ATF info is.

Posted: 11/14/2010 10:30:01 AM EDT

[#39]

damcv62:
I have purchased silencers from 2 local dealers using a trust. They fill out the form 4 which I sign, and they fill out line 15, every time. Just so you know.

Posted: 11/14/2010 11:41:51 AM EDT

[#40]

Quoted:

Quoted:
And just to be clear, if #15 has always had to have been filled out, I wouldn't have a problem. My problem is that I've had transfers done by the same examiner with in the last month approved with nothing in #15, and that the supervisor said that it doesn't have to be filled in, but to just do it to make her happy. That is what I have a problem with.

Well, that's where we have a different interpretation.

My own take –– and echoed by a former NFA Branch examiner –– is that #15 has always been neccessary for MGs, SBRs, SBS's, etc., though not for suppressors or AOWs.

Yes, you apparently have had some forms approved –– by a newbie examiner –– without #15 being filled out. My own take is that that was done in error. No, you don't need to correct/resubmit them (at least IMHO), but don't complain when a mistake is made in your favor. IMHO.

As far as Ted Clutter's comments via phone ... well, my longstanding opinion is that facts stated in phone conversations with BATFE are worth the paper they are written on. In other words, they are worthless, and may be due to either a miscommunication or a mental burp. Both of which I have had, repeatedly, in my life, so I am not criticising either you or Ted.

I do not see this as a change in ATF policy, because it is compliant with what I have understood to be policy which has existed for decades. Then again, maybe I've been wrong all these years, and there is some sinister manipulation going on.

Y'all are free to make your own call on this. But it does not bother me, and I'm a believer in the motto: Just because I'm paranoid doesn't mean ATF is not out to get me.

YMMV.

Chalk it up to the ATF being an bunch of mumbling idiots. I swear, the .gov wouldn't be able to tell their hand from their foot if they didn't have a 500 page manual on how to tell the differences, and even though they have the manual, no one even reads it, and or understand what it states.

I'm still waiting to hear back from the examiner to get her clarification on why she is approving forms with no standard. I look forward to that explanation.

And trust me, I understand that something said over the phone holds no weight with the ATF, or with anything for that matter. But I don't like the "oh, just make her happy go do it" instead of "let me get off my ass and go do my job and find out what it should be so we can get it done right" Thats what I have a problem with.

Posted: 11/14/2010 11:43:58 AM EDT

[#41]

Quoted:
damcy62 said "You have to send the cert of citizenship in for trusts. I've never had a dealer tell me otherwise."

I'm just citing...

From the November 2008 FFL newsletter.

The Articles of Incorporation or other documentation establishing the legal entity must be included with the Form 4 application. The documentation must identify a point of contact for the corporation or other entity and must be sufficient for ATF to establish the legitimacy of the existence of the corporation or other entity.

If the firearm being transferred is a machinegun, short-barreled rifle, short-barreled shotgun, or destructive device, an officer or director of the corporation or other entity must complete item 15 on the reverse side of the Form 4.

Items 13, 14, 16, and 17 of the Form 4 do not require completion for a transfer to a corporation or other entity nor is the submission of ATF F 5330.20, Certification of Compliance with 18 U.S.C. 922(g)(5)(B), required.

So, I'm guessing that martinsburg is just ignoring this or it has already been rescinded as so much other ATF info is.

And that is what I'm talking about. They don't even know what their 500 page manual calls for, but they are going to go ahead and make things up as they go. Why hasn't someone pointed that out to them?

Posted: 11/14/2010 5:01:21 PM EDT

[#42]

Taggity.

Posted: 11/15/2010 4:00:16 PM EDT

[#43]

Sooooo. Get a call today from Suzanne, I had called her to get her take on the whole thing.

She says that they had a memo sent out Oct 7th(which explains why the one for my M60 that was approved on Oct 1st was approved). And the memo says that all DD's, MG's, SBR's, SBS's, and AOW's have to have section #15 filled out for any entity, trust, corp, or personal transfer. But suppressors don't.

WTF over? Why don't suppressors have to have section #15 filled out???

Random much?

Posted: 11/15/2010 4:14:18 PM EDT

[#44]

FWIW, my recent (and first) suppressor I got approved in August, I filled out section 15 using "Molardog, Trustee" then applied my signature as such at the bottom of the section. Sounds like it they may not care either way you do it with a suppressor?

Posted: 11/15/2010 4:40:35 PM EDT

[#45]

triple tap

Posted: 11/15/2010 4:41:29 PM EDT

[#46]

verizon double tap

Posted: 11/15/2010 6:19:01 PM EDT

[#47]

Quoted:
FWIW, my recent (and first) suppressor I got approved in August, I filled out section 15 using "Molardog, Trustee" then applied my signature as such at the bottom of the section. Sounds like it they may not care either way you do it with a suppressor?

Right, but why? Why do suppressors not matter?

Posted: 11/15/2010 8:41:44 PM EDT

[#48]

Quoted:

Quoted:
FWIW, my recent (and first) suppressor I got approved in August, I filled out section 15 using "Molardog, Trustee" then applied my signature as such at the bottom of the section. Sounds like it they may not care either way you do it with a suppressor?

Right, but why? Why do suppressors not matter?

Because that is what the United States Code requires. The U.S.C. does not list the reasons for it, but somewhere back in the distant past two different lists of NFA items were enshrined in law. Once lists all NFA firearms types; the other list omits suppressors and AOWs.

You would have to do extensive research to find out why there are two different lists –– it could have been Congressional intent, it could have been a simple cut-and-paste error. But the two different lists are right there in the law, and over time, as new regulations were passed into law, some bills used the full list, others used the shorter one. ATF's forms are based on the relevant Code for each requirement.

If you'd like to read the relevant laws, read 18 USC 44, 18 USC 922 and 26 USC 53, plus the Code of Federal Regulations sections (27 CFR 478 & 479). You'll see that some laws regulate all NFA items; others only apply to MGs, SBRs, SBS's and DDs.

Posted: 11/16/2010 6:58:59 AM EDT

[#49]

Quoted:

Quoted:
FWIW, my recent (and first) suppressor I got approved in August, I filled out section 15 using "Molardog, Trustee" then applied my signature as such at the bottom of the section. Sounds like it they may not care either way you do it with a suppressor?

Right, but why? Why do suppressors not matter?

Because that is what the United States Code requires. The U.S.C. does not list the reasons for it, but somewhere back in the distant past two different lists of NFA items were enshrined in law. Once lists all NFA firearms types; the other list omits suppressors and AOWs.

You would have to do extensive research to find out why there are two different lists –– it could have been Congressional intent, it could have been a simple cut-and-paste error. But the two different lists are right there in the law, and over time, as new regulations were passed into law, some bills used the full list, others used the shorter one. ATF's forms are based on the relevant Code for each requirement.

If you'd like to read the relevant laws, read 18 USC 44, 18 USC 922 and 26 USC 53, plus the Code of Federal Regulations sections (27 CFR 478 & 479). You'll see that some laws regulate all NFA items; others only apply to MGs, SBRs, SBS's and DDs.

Right, and I get that. But why does AOW's have to have it filled out, and not suppressors? Why aren't both AOW's and suppressors listed under the same rules?

Posted: 11/16/2010 7:56:46 AM EDT

[#50]

Quoted:
I have always filled out section 15 and use a Trust.

Just assumed I had to as well. On form 1's, 4's for MGs, SBRs and Cans.

Hope it goes well for you Dam.

[ARCHIVED THREAD] - Trust transfers now need box #15 filled out on F4's(WTF update bottom 2) (Page 1 of 2)

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