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Posted: 1/9/2010 6:01:46 PM EDT
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Gang,
I read the NFA handbook and section 7.4 talks about names or "recognized abbreviations." I assume this refers to companies and my trust needs to be engraved fully, or at least with my name spelled out, ie, "John L. Smith RLT" The last few SBRs I did fell under the "old" rules, and I simply had "JLS RLT" engraved under the trigger guard. Now I have to engrave on the side of the receiver, as that is where the most room exists for lettering... Having said that, assuming my future engraving complies with the depth requirement, can I then Duracoat (or whatever) the receiver? If paint fills in the lettering, will I be out of compliance? Thanks. |
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Gang, I read the NFA handbook and section 7.4 talks about names or "recognized abbreviations." I assume this refers to companies and my trust needs to be engraved fully, or at least with my name spelled out, ie, "John L. Smith RLT" The last few SBRs I did fell under the "old" rules, and I simply had "JLS RLT" engraved under the trigger guard. Now I have to engrave on the side of the receiver, as that is where the most room exists for lettering... Having said that, assuming my future engraving complies with the depth requirement, can I then Duracoat (or whatever) the receiver? If paint fills in the lettering, will I be out of compliance? Thanks. Wow thats a good one. I'm gonna say NO you can't do that unless the engraving is easily observed and unobstructed. My non BATFE opinion. |
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Well the engraving would be on the side of the receiver (AR15), cut to required depth, and simply covered in a layer or two of Dura. Not filled in with paint, just a light coating. Thats a good one as I said. I'm gonna say ATF would have a problem with it because it would " obstruct " its legibility. Just as you can't put the engraved information under handguards anymore, etc... |
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Gang, I read the NFA handbook and section 7.4 talks about names or "recognized abbreviations." I assume this refers to companies and my trust needs to be engraved fully, or at least with my name spelled out, ie, "John L. Smith RLT" According to ATF, "RLT" is not a recognized abbreviation. You must engrave the entire name: John L. Smith Revokable Living Trust. The last few SBRs I did fell under the "old" rules, and I simply had "JLS RLT" engraved under the trigger guard. Now I have to engrave on the side of the receiver, as that is where the most room exists for lettering... There are no "new" and "old" engraving rules. You have had to engrave the entire name, or only use recognized abbreviations, since 1968. The "JLS RLT" is something that people started doing –– in violation of the regs –– and then ATF caught on and spelled out the existing rules for everyone. Having said that, assuming my future engraving complies with the depth requirement, can I then Duracoat (or whatever) the receiver? If paint fills in the lettering, will I be out of compliance? If the paint fills in the lettering so that they are less than the dept requirement, you will be out of compliance. Just engrave it a little deeper, so that post-coating it is still in compliance. Thanks. |
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So if the name of my trust is "TRC NFA TRUST" I can't use that on my "form 1" application and or as the receiver marking. I thought the trust could be named anything i wanted, am I wrong? If that is the ACTUAL name of your trust, you are GTG. The problem lies with abbreviating the ACTUAL name of the trust. If it was The Really Cool NFA Trust, you couldn't engrave TRC NFA Trust. |
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So if the name of my trust is "TRC NFA TRUST" I can't use that on my "form 1" application and or as the receiver marking. I thought the trust could be named anything i wanted, am I wrong? If that is the ACTUAL name of your trust, you are GTG. The problem lies with abbreviating the ACTUAL name of the trust. If it was The Really Cool NFA Trust, you couldn't engrave TRC NFA Trust. This. Plus you don't have to put anything in the name beyond "Trust" that you don't want to. Dump "Revocable Living" because that characteristic of the trust doesn't need to be in the name. Your own name doesn't need to be part of it either. If the trust documents call the trust "TRC Trust" then that's all you have to engrave. |
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Plus you don't have to put anything in the name beyond "Trust" that you don't want to. Dump "Revocable Living" because that characteristic of the trust doesn't need to be in the name. Your own name doesn't need to be part of it either. If the trust documents call the trust "TRC Trust" then that's all you have to engrave. Tony_K says NO: Quoted:
ATF examiners do not have authority to grant waivers to the engraving requirements. Only ATF Tech or Legal Branch have that authority. By approving your Form 1, the ATF examiner only gave you permission to make the SBR, not how to make it. If your engraving is not in compliance with federal law, then yes, your SBR itself is not in compliance with federal law as enforced by BATFE, regardless of what you wrote on the Form 1. I'm thinking about contacting the BATF to get some clarification on this in writing. I just want to get to the bottom of this and find the 100% correct answer. EDIT: I found this on m4carbine: I've been told by my ATF rep that it doesn't have to match as long as they've been made aware of the variance. I was directed to section 8.5.4 of the NFA handbook:
"8.5.4 Obtaining variances to the marking requirements. Requests for variances from the marking requirements should be submitted by letter to ATF’s Firearms Technology Branch (FTB) in duplicate. The requests should state the proposed variance and the reasons for the variance." In any case, it's best to contact the ATF directly about any questions you may have. Anything posted on the internet regarding ATF/NFA regulations should be taken with salt. Ultimately it's up to the individual to make sure that he or she is in compliance with the law. |
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I was saying WHEN NAMING A TRUST that you need to dump the "Revocable Living" part and give it a very short name. The BATFE wants your engraving to match the name of the trust-because the name of the trust is the name of the maker. If you name your trust something short, you engrave that EXACTLY.
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Plus you don't have to put anything in the name beyond "Trust" that you don't want to. Dump "Revocable Living" because that characteristic of the trust doesn't need to be in the name. Your own name doesn't need to be part of it either. If the trust documents call the trust "TRC Trust" then that's all you have to engrave. Tony_K says NO: Quoted:
ATF examiners do not have authority to grant waivers to the engraving requirements. Only ATF Tech or Legal Branch have that authority. By approving your Form 1, the ATF examiner only gave you permission to make the SBR, not how to make it. If your engraving is not in compliance with federal law, then yes, your SBR itself is not in compliance with federal law as enforced by BATFE, regardless of what you wrote on the Form 1. I'm thinking about contacting the BATF to get some clarification on this in writing. I just want to get to the bottom of this and find the 100% correct answer. EDIT: I found this on m4carbine: I've been told by my ATF rep that it doesn't have to match as long as they've been made aware of the variance. I was directed to section 8.5.4 of the NFA handbook:
"8.5.4 Obtaining variances to the marking requirements. Requests for variances from the marking requirements should be submitted by letter to ATF’s Firearms Technology Branch (FTB) in duplicate. The requests should state the proposed variance and the reasons for the variance." In any case, it's best to contact the ATF directly about any questions you may have. Anything posted on the internet regarding ATF/NFA regulations should be taken with salt. Ultimately it's up to the individual to make sure that he or she is in compliance with the law. |
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I wonder how Century Arms gets away with their engraving. It looks like it's done with a vibro etcher FYI, BATFE's size/depth requirement was instituted on January 30, 2002. Prior to that date, it was legal to engrave with a vibrapen. And if Century is currently engraving with a vibrapen ... well, those of us who bought "demilled" Uzi kits from Cole's Distributing in 2002-3 learned the hard way that not all importers always follow the rules to the letter. In the case of Cole's customers, it resulted in ATF deciding that the kits were not sufficiently demilled and thus were still live, unregistered MGs ... so ATF came knocking on the doors of everyone who bought an Uzi kit and demanding it back. (And AFAIK, Cole's has never reimbursed its Uzi-kit customers one single cent.) Particularly when it comes to NFA, I do not trust anyone –– individual or retailer. And I bend over backwards to comply with the law when there is even the slightest doubt, because I love my dogs and do not want them shot. Your Mileage May Vary. 
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| Century is still engraving with a vibrapen so I guess caveat emptor. I also agree on trusting manufacturers and dealers. I once purchased a Benelli M1 S90 with a pistol grip and a 7 shot mag tube from a dealer who added the ext. tube on his own. Once I realized the 922r faux pas, I restored it to the factory configuration. |
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The way this reads there is a good argument that you do not need to engrave.
6.2.1 Description of firearm. If an existing firearm or firearm receiver is being used, the name and location of the original manufacturer of the weapon should be entered in Block 4(a). If the applicant is making a completely new firearm, the applicant’s name and location should be entered in Block 4(a). The type of firearm being made, i.e., short barrel rifle, short barrel shotgun, any other weapon, silencer or destructive device, is to be entered in Block 4(b). The caliber or gauge of the firearm is to be entered in Block 4(c). If a model designation has been assigned to the firearm, that designation is to be placed in Block 4(d). If the weapon has no model designation, enter “none” in Block 4(d). The length of the barrel is to be entered, in inches, in Block 4(e) and the overall length of the firearm is to be entered, in inches, in Block 4(f). All NFA firearms must be identified by a serial number and other specified markings95. If an existing firearm is being used in the making of the NFA weapon, and that firearm is serialized, the existing serial number should be used (unless it duplicates a serial number already used by the maker on Form 1) and entered in Block 4(g). If the weapon is of new manufacture, the applicant must assign a unique serial number and enter it in Block 4(g). For example, a unique serial number could be composed of at least 4 digits preceded by the initials of the maker. NOTE: alpha characters, e.g., a name, will not be accepted as a serial number. If a name is to be used, there must be at least one numeric character in addition to the alpha characters. The serial number must be engraved or stamped on the receiver of the firearm and the caliber, model, and identification of the maker must be engraved on the barrel or frame or receiver of the weapon.96 The marking and identification requirements for a maker are the same as for a manufacturer. Refer to section 7.4 for a detailed discussion of the requirements. |
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The way this reads there is a good argument that you do not need to engrave. 6.2.1 Description of firearm. If an existing firearm or firearm receiver is being used, the name and location of the original manufacturer of the weapon should be entered in Block 4(a). If the applicant is making a completely new firearm, the applicant’s name and location should be entered in Block 4(a). The type of firearm being made, i.e., short barrel rifle, short barrel shotgun, any other weapon, silencer or destructive device, is to be entered in Block 4(b). The caliber or gauge of the firearm is to be entered in Block 4(c). If a model designation has been assigned to the firearm, that designation is to be placed in Block 4(d). If the weapon has no model designation, enter “none” in Block 4(d). The length of the barrel is to be entered, in inches, in Block 4(e) and the overall length of the firearm is to be entered, in inches, in Block 4(f). All NFA firearms must be identified by a serial number and other specified markings95. If an existing firearm is being used in the making of the NFA weapon, and that firearm is serialized, the existing serial number should be used (unless it duplicates a serial number already used by the maker on Form 1) and entered in Block 4(g). If the weapon is of new manufacture, the applicant must assign a unique serial number and enter it in Block 4(g). For example, a unique serial number could be composed of at least 4 digits preceded by the initials of the maker. NOTE: alpha characters, e.g., a name, will not be accepted as a serial number. If a name is to be used, there must be at least one numeric character in addition to the alpha characters. The serial number must be engraved or stamped on the receiver of the firearm and the caliber, model, and identification of the maker must be engraved on the barrel or frame or receiver of the weapon.96 The marking and identification requirements for a maker are the same as for a manufacturer. Refer to section 7.4 for a detailed discussion of the requirements. A Form 1 is an application to make and register an NFA Firearm –– one which did not previously exist. If you are using an existing Title 1 firearm as the host, you need to include that info on the Form 1 –– but you are the maker of record of the NFA item. So you need to engrave it with your name/city/state. |
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I need to jump in a beat a dead horse....
If I put my full middle name on the Form 1 for my SBR, does that then need to go into the engraving? If my name was: John Randy Smith Am I engraving: (1) John Randy Smith (2) John R. Smith (3) John Smith (4) J. Smith (5) J. R. Smith (6) Other |
Man, that poor horse!
OK, let's get in the way-back machine. Once upon a time, you could have engraved 1, 2, 3 or 5. Since the internet commandos made folks aware that they were engraving JRS RLT for a Form 1 filed in the name of the John Randy Smith Revokable Living Trust, ATF has announced that you must engrave the full name as it appears on the Form 1 (and, in the case of a trust, as it appears on the trust paperwork). Period. Sigh. Sounds like you must spell out all three names, to be in compliance with the stated policy of BATFE. Now, I have never heard of anyone prosecuted for improper engraving. At worst, they confiscate your NFA firearm and re-engrave it for you, to their spex, and return it a year later. So gauge the risk and potential loss, and decide for yourself.
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I think people get way too literal in naming their trusts. If you use a simpler name for your trust, your engraving can be simpler. So while you MUST engrave the whole name of the trust, the name itself doesn't need to be lengthy.
I thought about this in naming my trust, but that was before the more thorough enforcement of "the whole name" thing. So with my trust named "She & He Shooter Trust" (you don't have to put "revocable" or "living" in the name), I had "S&H Shooter Trust" engraved as the name on the lower. That was over a year ago, and about the time my stamp came back they started specifically asking applicants to provide exactly what they engraved on the application. Any new SBRs I make will have to say "She & He Shooter Trust" Still, at 1/8" tall, my engraving covers a very small amount of real estate, and even with the longer name engraved it won't take up a lot of space. Edit: Let me reemphasize-I am talking about two or three steps before doing the engraving, when you originally create the trust in the first place. Nobody should have anything engraved until their trust is established. I'm talking about naming the trust when it's first drawn up, so that the name of the trust, that you enter on the Form 1 and have engraved not only match but are also sufficiently brief and concise. I've made the same suggestion before and it's been construed to mean that I suggested using some sort of shorthand on the Form 1. That is NOT what I'm saying. I'm saying "START OUT by giving the trust a short name so your engraving can be short too." |
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I think people get way too literal in naming their trusts. If you use a simpler name for your trust, your engraving can be simpler. So while you MUST engrave the whole name of the trust, the name itself doesn't need to be lengthy. I thought about this in naming my trust, but that was before the more thorough enforcement of "the whole name" thing. So with my trust named "She & He Shooter Trust" (you don't have to put "revocable" or "living" in the name), I had "S&H Shooter Trust" engraved as the name on the lower. That was over a year ago, and about the time my stamp came back they started specifically asking applicants to provide exactly what they engraved on the application. Any new SBRs I make will have to say "She & He Shooter Trust" Still, at 1/8" tall, my engraving covers a very small amount of real estate, and even with the longer name engraved it won't take up a lot of space. Edit: Let me reemphasize-I am talking about two or three steps before doing the engraving, when you originally create the trust in the first place. Nobody should have anything engraved until their trust is established. I'm talking about naming the trust when it's first drawn up, so that the name of the trust, that you enter on the Form 1 and have engraved not only match but are also sufficiently brief and concise. I've made the same suggestion before and it's been construed to mean that I suggested using some sort of shorthand on the Form 1. That is NOT what I'm saying. I'm saying "START OUT by giving the trust a short name so your engraving can be short too." You are 100% correct. If you want short engravings, make sure the name of your trust –– as shown in the documentation supplied to BATFE –– is short. Here's the rejection letter one applicant received when they submitted a Form 1 with a long trust name, but listed a shortened version in 4H as their intended engraving: 
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I think people get way too literal in naming their trusts. If you use a simpler name for your trust, your engraving can be simpler. So while you MUST engrave the whole name of the trust, the name itself doesn't need to be lengthy. I thought about this in naming my trust, but that was before the more thorough enforcement of "the whole name" thing. So with my trust named "She & He Shooter Trust" (you don't have to put "revocable" or "living" in the name), I had "S&H Shooter Trust" engraved as the name on the lower. That was over a year ago, and about the time my stamp came back they started specifically asking applicants to provide exactly what they engraved on the application. Any new SBRs I make will have to say "She & He Shooter Trust" Still, at 1/8" tall, my engraving covers a very small amount of real estate, and even with the longer name engraved it won't take up a lot of space. Edit: Let me reemphasize-I am talking about two or three steps before doing the engraving, when you originally create the trust in the first place. Nobody should have anything engraved until their trust is established. I'm talking about naming the trust when it's first drawn up, so that the name of the trust, that you enter on the Form 1 and have engraved not only match but are also sufficiently brief and concise. I've made the same suggestion before and it's been construed to mean that I suggested using some sort of shorthand on the Form 1. That is NOT what I'm saying. I'm saying "START OUT by giving the trust a short name so your engraving can be short too." You are 100% correct. If you want short engravings, make sure the name of your trust –– as shown in the documentation supplied to BATFE –– is short. Here's the rejection letter one applicant received when they submitted a Form 1 with a long trust name, but listed a shortened version in 4H as their intended engraving: http://www.hunt101.com/data/500/trustengravingnotice.jpg That's weird because I didn't get that letter!! I had a long trust name on my form 1, but I put a shortened version in 4H as my intended engraving. My form 1 was approved and they sent me my stamp. |
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I actually didn't put anything in 4H and had my F1 approved. But that was an application that went in some time in November, 2008. It seems that around the beginning of 2009 examiners were being much more strict about having everything filled out completely and correctly.
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I think people get way too literal in naming their trusts. If you use a simpler name for your trust, your engraving can be simpler. So while you MUST engrave the whole name of the trust, the name itself doesn't need to be lengthy. I thought about this in naming my trust, but that was before the more thorough enforcement of "the whole name" thing. So with my trust named "She & He Shooter Trust" (you don't have to put "revocable" or "living" in the name), I had "S&H Shooter Trust" engraved as the name on the lower. That was over a year ago, and about the time my stamp came back they started specifically asking applicants to provide exactly what they engraved on the application. Any new SBRs I make will have to say "She & He Shooter Trust" Still, at 1/8" tall, my engraving covers a very small amount of real estate, and even with the longer name engraved it won't take up a lot of space. Edit: Let me reemphasize-I am talking about two or three steps before doing the engraving, when you originally create the trust in the first place. Nobody should have anything engraved until their trust is established. I'm talking about naming the trust when it's first drawn up, so that the name of the trust, that you enter on the Form 1 and have engraved not only match but are also sufficiently brief and concise. I've made the same suggestion before and it's been construed to mean that I suggested using some sort of shorthand on the Form 1. That is NOT what I'm saying. I'm saying "START OUT by giving the trust a short name so your engraving can be short too." You are 100% correct. If you want short engravings, make sure the name of your trust –– as shown in the documentation supplied to BATFE –– is short. Here's the rejection letter one applicant received when they submitted a Form 1 with a long trust name, but listed a shortened version in 4H as their intended engraving: http://www.hunt101.com/data/500/trustengravingnotice.jpg That's weird because I didn't get that letter!! I had a long trust name on my form 1, but I put a shortened version in 4H as my intended engraving. My form 1 was approved and they sent me my stamp. |
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