We are a licensed FFL/SOT.  I am helping facilitate the transfer of a machine gun currently on a Form 4 in another state to me for a customer and I decided to use the new Silencer Shop Form 4 barcode generator.  Pretty slick online tool and hopefully the barcodes do indeed speed things up.

Our FFL/SOT is licensed under our LLC and as such we note on our NFA forms that as the transferee, we are a "TRUST or LEGAL ENTITY".  When checking that box using the new online tool, it prompts me for "RESPONSIBLE PERSON" details just like it would for an individual customer who is acquiring an NFA item through their private trust since the 41F/P rule change.  This generated a form 5320.23 that I would need to send in along with photos and fingerprint cards for myself as a member of our LLC.

I understood why that may be the case for a individual non-licensed transferee but never heard of FFL/SOT holders having to send in the 5320.23 along with photos and fingerprint cards.  I called NFA branch this morning and they stated that I would indeed need to send in all that crap to get the Form 4 approved.

Have any of you run across this?

If that's what ATF told you I guess do as you were told?

One of the 41P changes is that yes, the responsible persons for a corp or LLC FFL/SOT must submit pics, prints, and the 5320.23 for a Title II transfer coming in on a Form 4.

And yes it's stupid.

Cite please?

The instructions on the Form 4.

Instruction 2d(5) on page 5 of the Form 4, there is no exemption for FFL/SOT's.  Or alternatively the phone call the other FFL/SOT made above.

The "it's stupid" comment is mine not from anyone at ATF.