Posted: 1/15/2016 2:04:38 PM EDT
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ATF 41F was added to the registry today so it is 180 days till any changes take place. That puts it on July 13th 2016.
We dug through the 248 pages and pulled out some highlights. We still have lawyers going through it but right now this is what we think are some important points. Check it out on our blog ATF 41F Was Published Today |
| So my first 2 NFA purchases are due to be approved probably in next month or so. I may be wrong but once i'm approved for those, my trust will not have to submit any fingerprints for my next 2 years of purchases? I had been debating if I should go ahead and add a couple family members now even though i have no cans approved. |
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So my first 2 NFA purchases are due to be approved probably in next month or so. I may be wrong but once i'm approved for those, my trust will not have to submit any fingerprints for my next 2 years of purchases? That's what I got out of the reading 41F too. The way it's written it makes it sound like if I buy something every year I'll never have to turn in a photo or fingerprints. It appears they are trying to get clarification from ATF on this. |
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That's what I got out of the reading 41F too. The way it's written it makes it sound like if I buy something every year I'll never have to turn in a photo or fingerprints. It appears they are trying to get clarification from ATF on this. Quoted:
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So my first 2 NFA purchases are due to be approved probably in next month or so. I may be wrong but once i'm approved for those, my trust will not have to submit any fingerprints for my next 2 years of purchases? That's what I got out of the reading 41F too. The way it's written it makes it sound like if I buy something every year I'll never have to turn in a photo or fingerprints. It appears they are trying to get clarification from ATF on this. I think y'all both need to read the document again. ETA: to be clear, I meant 41F...not the blog |
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I think y'all both need to read the document again. ETA: to be clear, I meant 41F...not the blog Quoted:
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So my first 2 NFA purchases are due to be approved probably in next month or so. I may be wrong but once i'm approved for those, my trust will not have to submit any fingerprints for my next 2 years of purchases? That's what I got out of the reading 41F too. The way it's written it makes it sound like if I buy something every year I'll never have to turn in a photo or fingerprints. It appears they are trying to get clarification from ATF on this. I think y'all both need to read the document again. ETA: to be clear, I meant 41F...not the blog If you’re registering using a trust or corporation (which is the best option for most customers) then, once the 41F rule goes into effect (13 Jul 16), you’ll need to submit both fingerprints and passport photos for every responsible person with the application. (This is the worst part of 41F.) Once you receive an approval under the new rules, you’ll be exempted from having to submit fingerprint cards or passport photos again for 2 years from the date of the most recent approval. (We’re still digging into how, exactly, this will be implemented.) It looks like everything that is submitted before 13 Jul 16 will be processed under the current rules. Everything submitted on or after 13 Jul 16 will be processed under the new rules. So if you submitted something before the date you will not be exempted from having to submit fingerprint cards or passport photos again for 2 years. Once you have something submitted and approved under the new rules, then you will be exempted from having to submit fingerprint cards or passport photos again for 2 years. That's just the way I interpret their interpretation. 
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Once you receive an approval under the new rules, you’ll be exempted from having to submit fingerprint cards or passport photos again for 2 years from the date of the most recent approval. (We’re still digging into how, exactly, this will be implemented.) That's not what the actual 41F says. That's what everybody has repeated because a couple people read it that way...but it doesn't say that. The 24 month window refers to the trust/corp documentation only. |
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Thank you for confirming i'll need to spend more money Big Waylon  To be clear...there are definitely people that disagree with me (on the 24-month deal only being for the trust/corp docs)...but I think it spells it out fairly clearly. However, I do think everybody agrees that you'll have to file the 5320.23 with prints/photos at least once for every responsible person, for the first application on or after the in effect date of 7/13/16. Definitely don't have to do anything for items already approved. So, if you never bought anything after 7/12/16, you're good to go. In case you're interested, here is my explanation of the 24-month issue. |
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That's not what the actual 41F says. That's what everybody has repeated because a couple people read it that way...but it doesn't say that. The 24 month window refers to the trust/corp documentation only. Quoted:
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Once you receive an approval under the new rules, you’ll be exempted from having to submit fingerprint cards or passport photos again for 2 years from the date of the most recent approval. (We’re still digging into how, exactly, this will be implemented.) That's not what the actual 41F says. That's what everybody has repeated because a couple people read it that way...but it doesn't say that. The 24 month window refers to the trust/corp documentation only. Yeah, I guess my second paragraph makes it sound like I was referring to the individual applicant. My bad.
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Yeah, I guess my second paragraph makes it sound like I was referring to the individual applicant. My bad. Quoted:
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Once you receive an approval under the new rules, you’ll be exempted from having to submit fingerprint cards or passport photos again for 2 years from the date of the most recent approval. (We’re still digging into how, exactly, this will be implemented.) That's not what the actual 41F says. That's what everybody has repeated because a couple people read it that way...but it doesn't say that. The 24 month window refers to the trust/corp documentation only. Yeah, I guess my second paragraph makes it sound like I was referring to the individual applicant. My bad. I'm not sure you actually caught the point I was trying to make. As I read it, there is no 24-month window for any applicant, whether individual/trust/corp, as far as photos and prints go. The 24-month window only pertains to providing a copy go the trust, articles of incorporation, etc...whatever "documentation" you're providing to establish the entity's validity. Regardless of who's submitting, or if you had prior approvals, prints and a <1 year photo will have to be submitted. I don't like it, but that's how I see it written. |
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I got it now! I went back and read the link you provided and I see where your coming from now and it makes sense. Thanks for the info. But, I hope I'm wrong!! 
Also curious about the "official taking fingerprints" wording, and if that does eliminate DIY prints or not. |
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Just wondering...the blog says:
There Will Be A 2-Year Exemption After An Approval It’s not 100% clear how this will work yet, but we’re sitting down with the ATF to get more details next week. The way we’re reading the ATF 41F ruling appears to indicate that you won’t need to provide fingerprint cards or a 5320.23 with photos – or even a copy of your trust, if you’ve had any approval within the preceding 2 year period and your trust hasn’t changed. It will be interesting to see if these applications get fast-tracked by the NFA Branch in some way… I have voiced an opinion that I didn't read it that way, and that only the trust/corp documentation gets the 24-month waiver, and have had several people at least see my point of view. One of them sent me an IM today to say that one of the SS employees (who I'll leave nameless) was told the same thing at SHOT...that photos and prints will be required with each submission. Anybody from SS willing to confirm or correct that info? |
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Thanks for the clarifications. Your recent blog post says, "you don’t have to send a copy of your trust if it hasn’t changed". Does amending a schedule A count as a change and does the amended schedule A have to be included? Good question, we only had so much time to talk to the ATF but we assume that simply adding or removing items from the schedule A doesn't constitute a change. The way we are reading it is if trustee, beneficiaries change, or wording of the trust. |
| So if you drop your trustees when you purchase, and then add them back once you receive your NFA item, can you then drop them again? I am thinking everything would have to be dated, etc., and it could be a pain in the rear, but would that keep you from having to submit multiple fingerprints/photos? Thinking of my kids that are listed on my trust. |