41P Drops:

[plodder]

If I am understanding the basics of this, the primary reason why I elected to form a trust in the first place still stands:

A trust allows all named responsible persons (RP, or trustees) to be in legal possession of the NFA items even if I am not present. It will just now require the additional hassle of every RP & myself to submit fingerprints and photo every 2 years.

What I still do not have an answer for is the "Grandfathering" of current trusts and the NFA items held in that trust: If nothing changes regarding RPs & NFA items currently in the trust, must the trustees & I submit the fingerprints and photos in order to continue "business as usual" with the trust?

 

[Aaron Baker]

No. You only have to submit fingerprints and photographs if you submit a new tax stamp application after the effective date of the regulation. These new rules affect transfers, not ownership.

Aaron

 

[rob_benj]

A question regarding the fingerprinting. Is there any specific reason a person couldn't just complete a fingerprint card themselves and send it in? Do you have to go to someone that is "trained" for it? You can order the cards themselves inexpensively online.

 

[Bartholomew Roberts]

Whoever does the fingerprints has to certify that those are your fingerprints (as confirmed by ID), so you can't do your own (or I imagine ATF would be unlikely to accept self-confirmation).

Also ATF mentioned that businesses, law enforcement, etc. are all OK to submit fingerprints - basically anyone who can meet the standards - although unlike other federal agencies, apparently ATF can still not receive electronic fingerprints.

 

[rjrivero]

This 24 month "grace period," does that mean if I have a trust, got an item in the last 24 months and NOTHING has changed, I can submit another item filling out only the form that states, nothing has changed? Or does each RP need to submit photos and fingerprints on the first item after this change goes into effect?

If you add an NFA item every 24 months, will there be no further requirements then to submit fingerprints/photos?

 

[kimberkid]

So if I submit my form 1 before this 160 day cutoff my forms are grandfathered even if my they aren't approved (due to a backlog) for 336 days like form 1's I filed a couple years ago?

 

[yugorpk]

Sure. If you e-file it goes pending immediately.

 

[kimberkid]

I thought so, but with the ATF ... you just never know