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Posted: 2/16/2016 11:01:55 AM EDT
[Last Edit: 3/7/2016 4:14:53 PM EDT by Zhukov]
41F may be finalized, but the forms necessary to implement it have not been. They will be published in the Federal Register on 2/17/2016 with a 60 day comment period.





Sixty days is all the time you have to get a comment in. Before you copy and paste something to send in, be aware that the agency is required to respond to all UNIQUE comments, arguments, challenges, or questions. In other words, 10,000 copies of the same letter requires them to answer it once. 10,000 unique questions or concerns requires the agency to answer all 10,000. I don't really care if you ask them how this will impact interstate commerce in aluminum and titanium, common components of suppressors, and if such an impact on commerce has been reviewed by other departments and any decrease in revenue having been figured into the federal budgeting process, just come up with something other than a form letter.





This is our chance to delay implementation of 41F, possibly until after the election.





Here are the pre-publication notices of the forms.





Application for Tax Exempt Transfer and Registration of Firearm





Application for Tax Paid Transfer and Registration of Firearm





Application to Make and Register a Firearm





I would encourage all of you to request copies of each of the forms from Mr. Gary Schaible. His name may be quite familiar to some of you:









If you have additional comments especially on the estimated public burden or associated response time, suggestions, or need a copy of the proposed information collection instrument with instructions or additional information, please contact Gary Schaible, Industry Liaison Analyst, Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), 99 New York Ave, NE, Washington, DC 20226 at email :


nfaombcomments@atf.gov
View Quote






I will update this post with links to the draft forms once they are released to either reginfo.gov or regulations.gov.





UPDATE #1





From what I can tell, the new forms are still not available at ATF.gov, reginfo.gov, or regulations.gov. If one of you sees them online before I update again, please PM me with the links.





You can request copies of the forms by sending email to Gary Schaible (Gary.N.Schaible@usdoj.gov or nfaombcomments@atf.gov).





In order for your comments to be considered, they must adhere to the rules. I'm going to quote one of the Federal Register notifications and then add a few extras:









Written comments and suggestions from the public and affected agencies concerning the proposed collection of information are encouraged. Your


comments should address one or more of the following four points:





1. Evaluate whether the proposed collection of information is necessary for the proper performance of the functions of the agency, including whether the information will have practical utility;





2. Evaluate the accuracy of the agency’s estimate of the burden of the proposed collection of information, including the validity of the methodology and assumptions used;





3. Evaluate whether and if so how the quality, utility, and clarity of the information to be collected can be enhanced; and





4. Minimize the burden of the collection of information on those who are to respond, including through the use of appropriate automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses.


View Quote






Extras:





5. No profanity. They won't publish your comment if you use profanity, and if they don't publish it they aren't likely to bother responding to it. Profane comments serve no purpose other than wasting your time.





6. No form letters. It is better for you to write your own message, even if it is short, for each comment or concern. They have to READ these comments and RESPOND to unique ones - form letters do absolutely nothing but make BATFE's job easier.





7. Read #1 - #4, above, closely. Ask questions that fall into one or more of those categories. Ask easy ones. Ask hard ones. Ask questions that will require research to answer. If you think up a question while sitting on the toilet, bust out that iPhone or Android phone and pop off another email to nfaombcomments@atf.gov! Think of one while driving? Send another email when you get where you are going! Fire for effect, but make no mistake, the goal here is to overwhelm BATFE and DOJ's ability to respond.





Update #2





I found the forms.





Application to Make and Register a Firearm (Form 1)





Application for Tax Paid Transfer and Registration of Firearm (Form 4)





Application for Tax Exempt Transfer and Registration of Firearm (Form 5)





Update #3 - Responsible Persons Form 5320.23





https://www.atf.gov/firearms/docs/form/national-firearms-act-nfa-responsible-person-questionnaire-omb-number-1140%E2%80%93new/download



<Untacked - the rules for tacked threads specify that the person who is tacking the thread must also specify when the thread is to be untacked -Z>


 
Link Posted: 2/16/2016 11:03:24 AM EDT
OST and subscribed.
Link Posted: 2/16/2016 11:12:12 AM EDT
Thanks for gathering all this and explaining how they are only going to reply to the same question once.  

Would it be possible to compile a list of the Pros and Cons of 41F?
Link Posted: 2/16/2016 11:54:01 AM EDT
In.
Link Posted: 2/16/2016 12:04:53 PM EDT
Yes.
Link Posted: 2/16/2016 12:12:12 PM EDT
Wasn't it originally going to be 180 days?
Link Posted: 2/16/2016 12:14:45 PM EDT
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Originally Posted By Michigan_Man:
Wasn't it originally going to be 180 days?
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You are correct, in a manner of speaking.

41F, which is to go into effect in July (180 days after publication in the Federal Register), requires changes to ATF Forms. Those changes require separate publication and review/comment periods. That is what this thread is about.

Essentially, 41F is impossible without those new forms, and those new forms are not yet approved and have not yet gone through their comment period.
Link Posted: 2/16/2016 12:16:32 PM EDT
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Originally Posted By Undefined:


You are correct, in a manner of speaking.

41F, which is to go into effect in July (180 days after publication in the Federal Register), requires changes to ATF Forms. Those changes require separate publication and review/comment periods. That is what this thread is about.

Essentially, 41F is impossible without those new forms, and those new forms are not yet approved and have not yet gone through their comment period.
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Originally Posted By Undefined:
Originally Posted By Michigan_Man:
Wasn't it originally going to be 180 days?


You are correct, in a manner of speaking.

41F, which is to go into effect in July (180 days after publication in the Federal Register), requires changes to ATF Forms. Those changes require separate publication and review/comment periods. That is what this thread is about.

Essentially, 41F is impossible without those new forms, and those new forms are not yet approved and have not yet gone through their comment period.


Yep. And I will add that from everything I've heard, the ATF is already working on a very tight timeline to get this in place in time. An overwhelming response here could put a hurt on them and their ambitions.
Link Posted: 2/16/2016 12:17:13 PM EDT
I'll comment again, although I never received a reply to my last comment which was one I wrote myself.
Link Posted: 2/16/2016 12:18:13 PM EDT
Discussion ForumsJump to Quoted PostQuote History
Originally Posted By ncthorn1623:


Yep. And I will add that from everything I've heard, the ATF is already working on a very tight timeline to get this in place in time. An overwhelming response here could put a hurt on them and their ambitions.
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Originally Posted By ncthorn1623:
Originally Posted By Undefined:
Originally Posted By Michigan_Man:
Wasn't it originally going to be 180 days?


You are correct, in a manner of speaking.

41F, which is to go into effect in July (180 days after publication in the Federal Register), requires changes to ATF Forms. Those changes require separate publication and review/comment periods. That is what this thread is about.

Essentially, 41F is impossible without those new forms, and those new forms are not yet approved and have not yet gone through their comment period.


Yep. And I will add that from everything I've heard, the ATF is already working on a very tight timeline to get this in place in time. An overwhelming response here could put a hurt on them and their ambitions.


It took them well over a year to respond to our 41P comments.

We have 60 days to pile on enough UNIQUE questions, comments, concerns, and clarifications to keep them busy until the next president is sworn into office.
Link Posted: 2/16/2016 12:20:29 PM EDT
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Originally Posted By MSC182:
I'll comment again, although I never received a reply to my last comment which was one I wrote myself.
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I believe in the "Comment a day keeps the 41F at bay" plan.

"How will this revised Form 1 take into consideration the needs of blind gun owners exercising their constitutionally enumerated right? Will a braille version be produced?"

"Will this new form be translated into Farsi, Arabic, and Pashtun to accommodate legal gun ownership of new citizens?"

"What Federal assistance is available to aid underprivileged gun owners in completing these forms?"

etc. etc. etc.
Link Posted: 2/16/2016 12:30:06 PM EDT
Tagged.  I'll put a comment together.



Something I did last time, I started with a form letter, then I altered it and added some of my own.  
Link Posted: 2/16/2016 12:32:16 PM EDT
Discussion ForumsJump to Quoted PostQuote History
Originally Posted By jaqufrost:
Tagged.  I'll put a comment together.

Something I did last time, I started with a form letter, then I altered it and added some of my own.  
View Quote


What we really need is a random comment generator. Sort of like the random comic generator (click here to waste time and laugh) only useful for our purposes.
Link Posted: 2/16/2016 12:45:04 PM EDT
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Originally Posted By Undefined:


What we really need is a random comment generator. Sort of like the random comic generator (click here to waste time and laugh) only useful for our purposes.
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Originally Posted By Undefined:
Originally Posted By jaqufrost:
Tagged.  I'll put a comment together.

Something I did last time, I started with a form letter, then I altered it and added some of my own.  


What we really need is a random comment generator. Sort of like the random comic generator (click here to waste time and laugh) only useful for our purposes.

feed a Markov text tool the comments from last time
Link Posted: 2/16/2016 1:07:04 PM EDT
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Originally Posted By RyJones:
Originally Posted By Undefined:
Originally Posted By jaqufrost:
Tagged.  I'll put a comment together.

Something I did last time, I started with a form letter, then I altered it and added some of my own.  


What we really need is a random comment generator. Sort of like the random comic generator (click here to waste time and laugh) only useful for our purposes.

feed a Markov text tool the comments from last time


Fascinating idea. I've never written a Markov tool, but the potential here is essentially a weaponization of the comments process. A motivated public, with the right toolset (e.g. a generator that produced sufficient random work product as to be indistinguishable from manually written comments) could easily cripple a department's ability to respond.
Link Posted: 2/16/2016 1:10:00 PM EDT
Discussion ForumsJump to Quoted PostQuote History
Originally Posted By Undefined:


Fascinating idea. I've never written a Markov tool, but the potential here is essentially a weaponization of the comments process. A motivated public, with the right toolset (e.g. a generator that produced sufficient random work product as to be indistinguishable from manually written comments) could easily cripple a department's ability to respond.
View Quote View All Quotes
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Originally Posted By Undefined:
Originally Posted By RyJones:
Originally Posted By Undefined:
Originally Posted By jaqufrost:
Tagged.  I'll put a comment together.

Something I did last time, I started with a form letter, then I altered it and added some of my own.  


What we really need is a random comment generator. Sort of like the random comic generator (click here to waste time and laugh) only useful for our purposes.

feed a Markov text tool the comments from last time


Fascinating idea. I've never written a Markov tool, but the potential here is essentially a weaponization of the comments process. A motivated public, with the right toolset (e.g. a generator that produced sufficient random work product as to be indistinguishable from manually written comments) could easily cripple a department's ability to respond.


they're easy to write and the training corpus is digital, so... all you need are people to copyedit before they sign the comment.
Link Posted: 2/16/2016 1:13:48 PM EDT
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Originally Posted By RyJones:


they're easy to write and the training corpus is digital, so... all you need are people to copyedit before they sign the comment.
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Originally Posted By RyJones:
Originally Posted By Undefined:
Originally Posted By RyJones:
Originally Posted By Undefined:
Originally Posted By jaqufrost:
Tagged.  I'll put a comment together.

Something I did last time, I started with a form letter, then I altered it and added some of my own.  


What we really need is a random comment generator. Sort of like the random comic generator (click here to waste time and laugh) only useful for our purposes.

feed a Markov text tool the comments from last time


Fascinating idea. I've never written a Markov tool, but the potential here is essentially a weaponization of the comments process. A motivated public, with the right toolset (e.g. a generator that produced sufficient random work product as to be indistinguishable from manually written comments) could easily cripple a department's ability to respond.


they're easy to write and the training corpus is digital, so... all you need are people to copyedit before they sign the comment.


Or an app version "Click here to submit a comment".

To the best of my knowledge, there is no limit to the number of comments an individual can submit.
Link Posted: 2/16/2016 1:21:01 PM EDT
What is 41F?  I guess I hadn't heard of this one...
Link Posted: 2/16/2016 1:21:43 PM EDT
Thanks for the heads up. I'll write something unique
Link Posted: 2/16/2016 1:22:54 PM EDT
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Originally Posted By Saladman:
What is 41F?  I guess I hadn't heard of this one...
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41P became 41F.

Whether this happened as a result of some form of obfuscation or as a result of a typo, I do not know.
Link Posted: 2/16/2016 1:23:22 PM EDT

Discussion ForumsJump to Quoted PostQuote History
Originally Posted By Saladman:


What is 41F?  I guess I hadn't heard of this one...
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It's the final version of 41P.  This is the rule that makes Trust submissions include fingerprints.

 
Link Posted: 2/16/2016 1:23:47 PM EDT

Discussion ForumsJump to Quoted PostQuote History
Originally Posted By Undefined:
41P became 41F.



Whether this happened as a result of some form of obfuscation or as a result of a typo, I do not know.
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Originally Posted By Undefined:



Originally Posted By Saladman:

What is 41F?  I guess I hadn't heard of this one...




41P became 41F.



Whether this happened as a result of some form of obfuscation or as a result of a typo, I do not know.
I thought it was because P was for Proposed and F was for Final.

 
Link Posted: 2/16/2016 1:28:21 PM EDT
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Originally Posted By jaqufrost:
I thought it was because P was for Proposed and F was for Final.  
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Originally Posted By jaqufrost:
Originally Posted By Undefined:
Originally Posted By Saladman:
What is 41F?  I guess I hadn't heard of this one...


41P became 41F.

Whether this happened as a result of some form of obfuscation or as a result of a typo, I do not know.
I thought it was because P was for Proposed and F was for Final.  


That would be logical.

I assumed it was a typo. That would align more with what I expect out of BATFE.
Link Posted: 2/16/2016 1:44:08 PM EDT
So I assume the only way to respond is by emailing the email address listed at the top, like there is no website to leave the comments?
Link Posted: 2/16/2016 1:46:04 PM EDT
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Originally Posted By jaqufrost:
I thought it was because P was for Proposed and F was for Final.  
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Originally Posted By jaqufrost:
Originally Posted By Undefined:
Originally Posted By Saladman:
What is 41F?  I guess I hadn't heard of this one...


41P became 41F.

Whether this happened as a result of some form of obfuscation or as a result of a typo, I do not know.
I thought it was because P was for Proposed and F was for Final.  


This is true
Link Posted: 2/16/2016 1:46:39 PM EDT
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Originally Posted By rebelcovehunter:
So I assume the only way to respond is by emailing the email address listed at the top, like there is no website to leave the comments?
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The webpage will likely be up tomorrow.
Link Posted: 2/16/2016 1:51:34 PM EDT
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Originally Posted By ncthorn1623:


The webpage will likely be up tomorrow.
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Originally Posted By ncthorn1623:
Originally Posted By rebelcovehunter:
So I assume the only way to respond is by emailing the email address listed at the top, like there is no website to leave the comments?


The webpage will likely be up tomorrow.


Thanks!
Link Posted: 2/16/2016 1:54:06 PM EDT
I've got this thread bookmarked. I'll do a few comments a day once it goes live.

FATF
FBHO
Link Posted: 2/16/2016 1:55:22 PM EDT
Tag.



Thanks Undefined.
Link Posted: 2/16/2016 1:57:00 PM EDT
It makes it easier for individuals why should I care? I got mine.
Link Posted: 2/16/2016 2:21:16 PM EDT
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Originally Posted By Sheddy:
It makes it easier for individuals why should I care? I got mine.
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they_they_came_for_me_poem.pdf
Link Posted: 2/16/2016 2:22:25 PM EDT
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Originally Posted By Sheddy:
It makes it easier for individuals why should I care? I got mine.
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Trading one freedom for another is not how we win.
Link Posted: 2/16/2016 2:24:26 PM EDT
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Originally Posted By Sheddy:
It makes it easier for individuals why should I care? I got mine.
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Link Posted: 2/16/2016 2:25:49 PM EDT
skin tagging
Link Posted: 2/16/2016 2:31:45 PM EDT
I'm not convinced we should oppose 41f as written.  It makes it slightly more difficult for trusts, MUCH easier for individuals.  The longer 41f is delayed, the longer most citizens in Illinois will have to wait to get SBRs.
Link Posted: 2/16/2016 2:38:30 PM EDT
This makes me feel stupid, because I don't speak Federal Process, but essentially the workflow of "submitting a comment" is:

Once published to the federal register, comment period opens

1. Write your comment based on the documents linked in the OP
2. Submit those comments to nfaombcomments@atf.gov

?
Link Posted: 2/16/2016 2:41:22 PM EDT
Discussion ForumsJump to Quoted PostQuote History
Originally Posted By Kuraki:
This makes me feel stupid, because I don't speak Federal Process, but essentially the workflow of "submitting a comment" is:

Once published to the federal register, comment period opens

1. Write your comment based on the documents linked in the OP
2. Submit those comments to nfaombcomments@atf.gov

?
View Quote


Comments can also be submitted online. The pages for that won't be available until tomorrow.

I posted this a day early.
Link Posted: 2/16/2016 2:41:56 PM EDT
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Originally Posted By backbencher:
I'm not convinced we should oppose 41f as written.  It makes it slightly more difficult for trusts, MUCH easier for individuals.  The longer 41f is delayed, the longer most citizens in Illinois will have to wait to get SBRs.
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The longer it's delayed the longer E-Forms is useful for Form 1 makers.

I'm not saying one is more important than the other.  But I do have an idea which would put more NFA items in a greater number of peoples hands for a given period of time, if that were a goal.  I would personally submit 10 over the next year if I had a year.  I will likely only submit 5 before July.  But I do see your point.
Link Posted: 2/16/2016 2:43:26 PM EDT
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Originally Posted By Undefined:


Comments can also be submitted online. The pages for that won't be available until tomorrow.

I posted this a day early.
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Originally Posted By Undefined:
Originally Posted By Kuraki:
This makes me feel stupid, because I don't speak Federal Process, but essentially the workflow of "submitting a comment" is:

Once published to the federal register, comment period opens

1. Write your comment based on the documents linked in the OP
2. Submit those comments to nfaombcomments@atf.gov

?


Comments can also be submitted online. The pages for that won't be available until tomorrow.

I posted this a day early.


But, once they're published, emailing a comment to that address is a valid way of submitting a comment?
Link Posted: 2/16/2016 2:44:06 PM EDT
Discussion ForumsJump to Quoted PostQuote History
Originally Posted By backbencher:
I'm not convinced we should oppose 41f as written.  It makes it slightly more difficult for trusts, MUCH easier for individuals.  The longer 41f is delayed, the longer most citizens in Illinois will have to wait to get SBRs.
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The goal should be to delay and rewrite it such that all it does is remove CLEO sign off.

It is easier to get a watered down rewrite if the full version never goes into effect.
Link Posted: 2/16/2016 2:45:06 PM EDT
Discussion ForumsJump to Quoted PostQuote History
Originally Posted By Kuraki:


But, once they're published, emailing a comment to that address is a valid way of submitting a comment?
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Originally Posted By Kuraki:
Originally Posted By Undefined:
Originally Posted By Kuraki:
This makes me feel stupid, because I don't speak Federal Process, but essentially the workflow of "submitting a comment" is:

Once published to the federal register, comment period opens

1. Write your comment based on the documents linked in the OP
2. Submit those comments to nfaombcomments@atf.gov

?


Comments can also be submitted online. The pages for that won't be available until tomorrow.

I posted this a day early.


But, once they're published, emailing a comment to that address is a valid way of submitting a comment?


Yes, that is correct. Once they are published you will be able to see the actual proposed forms as well (instead of just the notice that they wish to change them).
Link Posted: 2/16/2016 2:48:33 PM EDT
Discussion ForumsJump to Quoted PostQuote History
Originally Posted By Saladman:
What is 41F?  I guess I hadn't heard of this one...
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Thats a good question for them.
Link Posted: 2/16/2016 2:49:08 PM EDT
Discussion ForumsJump to Quoted PostQuote History
Originally Posted By Undefined:


The goal should be to delay and rewrite it such that all it does is remove CLEO sign off.

It is easier to get a watered down rewrite if the full version never goes into effect.
View Quote View All Quotes
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Originally Posted By Undefined:
Originally Posted By backbencher:
I'm not convinced we should oppose 41f as written.  It makes it slightly more difficult for trusts, MUCH easier for individuals.  The longer 41f is delayed, the longer most citizens in Illinois will have to wait to get SBRs.


The goal should be to delay and rewrite it such that all it does is remove CLEO sign off.

It is easier to get a watered down rewrite if the full version never goes into effect.


Exactly.

Furthermore, I want them to be forced to clarify 41F's impact on eForms.
Link Posted: 2/16/2016 3:09:13 PM EDT
Discussion ForumsJump to Quoted PostQuote History
Originally Posted By Undefined:


Yes, that is correct. Once they are published you will be able to see the actual proposed forms as well (instead of just the notice that they wish to change them).
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Originally Posted By Undefined:
Originally Posted By Kuraki:
Originally Posted By Undefined:
Originally Posted By Kuraki:
This makes me feel stupid, because I don't speak Federal Process, but essentially the workflow of "submitting a comment" is:

Once published to the federal register, comment period opens

1. Write your comment based on the documents linked in the OP
2. Submit those comments to nfaombcomments@atf.gov

?


Comments can also be submitted online. The pages for that won't be available until tomorrow.

I posted this a day early.


But, once they're published, emailing a comment to that address is a valid way of submitting a comment?


Yes, that is correct. Once they are published you will be able to see the actual proposed forms as well (instead of just the notice that they wish to change them).


Thanks.

I'll get my comments in order, unique for each form.  

If time allows, I will write more unique comments and post them here for others to submit.
Link Posted: 2/16/2016 3:38:25 PM EDT
Originally Posted By Undefined:
41F may be finalized, but the forms necessary to implement it have not been. They will be published in the Federal Register on 2/17/2016 with a 60 day comment period.

Sixty days is all the time you have to get a comment in. Before you copy and paste something to send in, be aware that the agency is required to respond to all UNIQUE comments, arguments, challenges, or questions. In other words, 10,000 copies of the same letter requires them to answer it once. 10,000 unique questions or concerns requires the agency to answer all 10,000. I don't really care if you ask them how this will impact interstate commerce in aluminum and titanium, common components of suppressors, and if such an impact on commerce has been reviewed by other departments and any decrease in revenue having been figured into the federal budgeting process, just come up with something other than a form letter.

This is our chance to delay implementation of 41F, possibly until after the election.

Here are the pre-publication notices of the forms.

Application for Tax Exempt Transfer and Registration of Firearm

Application for Tax Paid Transfer and Registration of Firearm

Application to Make and Register a Firearm

I would encourage all of you to request copies of each of the forms from Mr. Gary Schaible. His name may be quite familiar to some of you:


If you have additional comments especially on the estimated public burden or associated response time, suggestions, or need a copy of the proposed information collection instrument with instructions or additional information, please contact Gary Schaible, Industry Liaison Analyst, Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), 99 New York Ave, NE, Washington, DC 20226 at email :
nfaombcomments@atf.gov
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I will update this post with links to the draft forms once they are released to either reginfo.gov or regulations.gov.
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Thanks for the heads-up, emailing him now to request forms and will be submitting comments.
Link Posted: 2/16/2016 4:11:08 PM EDT
Serious question. Not trolling.
Why exactly are we trying to delay 41F?
The inability to file form 1's electronically.
Trusts have to send prints and photos.
Other than that what are the negatives?
I think 41F is a good thing. It enables people in states that have CLEO that won't sign be able to obtain NFA items.
I have a trust I use for my NFA purchases and I will just amend it so that I am sole trustee with my beneficiary being my child.
Only I will have to send photo and prints. Same as an individual.
So why delay?

Tagging for answer.
Link Posted: 2/16/2016 4:19:36 PM EDT
tagged , in , all that good stuff
Link Posted: 2/16/2016 4:30:41 PM EDT
Why you guys tryin' to delay my freedoms and stuff?
Link Posted: 2/16/2016 6:56:02 PM EDT
Discussion ForumsJump to Quoted PostQuote History
Originally Posted By Undefined:


The goal should be to delay and rewrite it such that all it does is remove CLEO sign off.

It is easier to get a watered down rewrite if the full version never goes into effect.
View Quote View All Quotes
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Originally Posted By Undefined:
Originally Posted By backbencher:  I'm not convinced we should oppose 41f as written.  It makes it slightly more difficult for trusts, MUCH easier for individuals.  The longer 41f is delayed, the longer most citizens in Illinois will have to wait to get SBRs.


The goal should be to delay and rewrite it such that all it does is remove CLEO sign off.

It is easier to get a watered down rewrite if the full version never goes into effect.


You are gambling that we would get a President who would pay any attention to this stuff once elected.  We already have a work-around for multiple trustees - multiple trusts, and add the extra trustees after the stamp for the new item comes back.  Getting rid of the CLEO signoff is huge, and will get many more folks into the NFA game who wouldn't otherwise.  I agree that photos & fingerprints is a pain in the ass, but given that we can do both @ home, and only for a couple of trustees, I don't see this is a battle worth fighting, particularly in an election year w/ the Supreme Court in the balance.  Our energies are best devoted on the wider front than this specific skirmish that we've largely already won.  And the longer we delay the implementation the more we penalize the folks in Illinois.
Link Posted: 2/16/2016 6:56:49 PM EDT


       
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Originally Posted By Rex_Allen:


Serious question. Not trolling.

Why exactly are we trying to delay 41F?

The inability to file form 1's electronically.

Trusts have to send prints and photos.

Other than that what are the negatives?

I think 41F is a good thing. It enables people in states that have CLEO that won't sign be able to obtain NFA items.

I
have a trust I use for my NFA purchases and I will just amend it so
that I am sole trustee with my beneficiary being my child.

Only I will have to send photo and prints. Same as an individual.

So why delay?



Tagging for answer.
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This is not the thread you're looking for.  We have other threads, un-archived, with this very topic discussed to death.



 



 
Link Posted: 2/16/2016 6:57:47 PM EDT

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Originally Posted By backbencher:
You are gambling that we would get a President who would pay any attention to this stuff once elected.  We already have a work-around for multiple trustees - multiple trusts, and add the extra trustees after the stamp for the new item comes back.  Getting rid of the CLEO signoff is huge, and will get many more folks into the NFA game who wouldn't otherwise.  I agree that photos & fingerprints is a pain in the ass, but given that we can do both @ home, and only for a couple of trustees, I don't see this is a battle worth fighting, particularly in an election year w/ the Supreme Court in the balance.  Our energies are best devoted on the wider front than this specific skirmish that we've largely already won.  And the longer we delay the implementation the more we penalize the folks in Illinois.
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Originally Posted By backbencher:



Originally Posted By Undefined:


Originally Posted By backbencher:  I'm not convinced we should oppose 41f as written.  It makes it slightly more difficult for trusts, MUCH easier for individuals.  The longer 41f is delayed, the longer most citizens in Illinois will have to wait to get SBRs.




The goal should be to delay and rewrite it such that all it does is remove CLEO sign off.



It is easier to get a watered down rewrite if the full version never goes into effect.




You are gambling that we would get a President who would pay any attention to this stuff once elected.  We already have a work-around for multiple trustees - multiple trusts, and add the extra trustees after the stamp for the new item comes back.  Getting rid of the CLEO signoff is huge, and will get many more folks into the NFA game who wouldn't otherwise.  I agree that photos & fingerprints is a pain in the ass, but given that we can do both @ home, and only for a couple of trustees, I don't see this is a battle worth fighting, particularly in an election year w/ the Supreme Court in the balance.  Our energies are best devoted on the wider front than this specific skirmish that we've largely already won.  And the longer we delay the implementation the more we penalize the folks in Illinois.
You're welcome to not participate.



 
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