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Suppressors Notice from Trust Attorney for Sparrow Can....

O

ok6.5

Private
Full Member
Minuteman
Dec 7, 2012
8
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73
Oklahoma
This is my first post. I just received an email from my trust attorney stating that he had received a notice from the BATF concerning the use of a trust with multiple people in the trust. I had mailed the paper work, check, pics, prints, etc to the BATF back in about July or August. Myself, my son, my wife and my daughter are also listed in the trust, but only my prints and pics were necessary, based on earlier applications for identically the same thing. The BATF had approved earlier apps for others, but now, they've decided to rewrite the regs concerning multiple people on trusts. My app was for the Sparrow silencer and I added my family to the trust, with the Sparrow being in the trust. Based on the new email, the regs are being re-written to require all people in the trust to submit prints, pics, etc. The attorney was notified this week but not sure if it was due to only my application, or based on the many, many he's done previously. I still don't know the status of my application, but felt it would be good to pass this on. If you're putting anything in a trust, the new regs will require information on all members of the trust. At least, thats what the notice from the BATF indicates. Nice to hear after waiting 7 months.

Here's the exact advisory I received:

Advisory: Currently, the BATF is working on revised regulations pertaining to NFA trust applications. It may be that the final regulations require responsible persons, as defined in the reg, to provide fingerprint cards and photo IDs even when using an NFA trust. Under the gun trust that I use, this would include all trustees of the NFA trust. Another proposed change is to do away with the CLEO approval, but require copies of your application and stamp be sent to the CLEO upon registration.

 
Re: Notice from Trust Attorney for Sparrow Can....

That is interesting.. I have a few suppressor under a trust, and there was no requirement for finger prints or photos when using a trust. I am no expert by no means. Maybe things have changed in the last year since I got a "can". I thought you only needed photo and finger prints if you were filing them as an individual? Good luck sorting it all out sorry about your paperwork hold up.

OK just saw what was sent to you.. Sounds like BS. If they are in the process of changing the law then they should just use what is already on the books!! Sounds like you got a bad processor at the aft
 
Re: Notice from Trust Attorney for Sparrow Can....

Key words. BATF is working on. ie not in effect yet but probably coming
 
Re: Notice from Trust Attorney for Sparrow Can....

That's the issue. All NFA trusts for this attorney have not required anything for 'other' members in the trust, but DID have requirements for the primary, at least that's how he's done all of them in Oklahoma. Now, he just received this advisory and passed it on to me. Not sure where this puts my application though.
 
Re: Notice from Trust Attorney for Sparrow Can....

another quote. It may be that the final regulations require responsible persons. The shit storm will come if/when they change. They would have to make it where any appication recieved after x date or it would screw up six months of forms.
Theres a thread on this down some
 
Re: Notice from Trust Attorney for Sparrow Can....

<div class="ubbcode-block"><div class="ubbcode-header">Originally Posted By: ok6.5</div><div class="ubbcode-body">This is my first post. I just received an email from my trust attorney stating that he had received a notice from the BATF concerning the use of a trust with multiple people in the trust. I had mailed the paper work, check, pics, prints, etc to the BATF back in about July or August. Myself, my son, my wife and my daughter are also listed in the trust, but only my prints and pics were necessary, based on earlier applications for identically the same thing. The BATF had approved earlier apps for others, but now, they've decided to rewrite the regs concerning multiple people on trusts. My app was for the Sparrow silencer and I added my family to the trust, with the Sparrow being in the trust. Based on the new email, the regs are being re-written to require all people in the trust to submit prints, pics, etc. The attorney was notified this week but not sure if it was due to only my application, or based on the many, many he's done previously. I still don't know the status of my application, but felt it would be good to pass this on. If you're putting anything in a trust, the new regs will require information on all members of the trust. At least, thats what the notice from the BATF indicates. Nice to hear after waiting 7 months.

Here's the exact advisory I received:

Advisory: Currently, the BATF is working on revised regulations pertaining to NFA trust applications. It may be that the final regulations require responsible persons, as defined in the reg, to provide fingerprint cards and photo IDs even when using an NFA trust. Under the gun trust that I use, this would include all trustees of the NFA trust. Another proposed change is to do away with the CLEO approval, but require copies of your application and stamp be sent to the CLEO upon registration.

</div></div>

Curious as to why a lawyer received this notification, is he an SOT as well?
 
Re: Notice from Trust Attorney for Sparrow Can....

This ain't passin the smell test. I don't believe the batfe would send notice to your attorney and not you or your dealer. Second, there's no requirement for prints or photos when using a trust YET! That said they simply have to follow there own rules until they change them.
 
Re: Notice from Trust Attorney for Sparrow Can....

<div class="ubbcode-block"><div class="ubbcode-header">Originally Posted By: Killswitch Engage</div><div class="ubbcode-body">This ain't passin the smell test. I don't believe the batfe would send notice to your attorney and not you or your dealer. Second, there's no requirement for prints or photos when using a trust YET! That said they simply have to follow there own rules until they change them. </div></div>

This.

I'm mailing off paperwork for stamp number 9 tomorrow and I've never submitted prints, pics or CLEO sign off for any of them. My dealer has not mentioned anything about it either and he sold 10 Sparrows from 1 pm yesterday to 5 pm today, with mine being the first he received money for.

I'd have to see the letter for myself.
 
Re: Notice from Trust Attorney for Sparrow Can....

<div class="ubbcode-block"><div class="ubbcode-header">Originally Posted By: Killswitch Engage</div><div class="ubbcode-body">This ain't passin the smell test. I don't believe the batfe would send notice to your attorney and not you or your dealer. Second, there's no requirement for prints or photos when using a trust YET! That said they simply have to follow there own rules until they change them. </div></div>

Exactly!

I am an 07/02 manufacturer and haven't received any notices or anything because NOTHING HAS HAPPENED and no changes have been made.

I would suggest that you obtain a copy of the notice and verify it with the ATF yourself before complying. If your lawyer will not make a copy of it or scan/email it to you then that should say something as well.

This smells terrible.
 
Re: Notice from Trust Attorney for Sparrow Can....

The trust was setup by this attorney, specifically for the Sparrow. He has setup several hundred trusts for similar purposes and was highly recommended by Cold Hand Arms. They have an impeccable reputation locally. The attorney's name is on the trust and I assume since he's done so many of them, he's probably been notified by the BATF. I'm hoping that it's not specifically about mine, but rather concerning all future NFA trusts. Again, this is an advisory. It says what it says and I'll post more when I get even more specifics. Not sure what the 'smell' test is, since the attorney, the dealer and myself included have done things exactly as required. I have researched it enough to know that for a while. the ATF questioned Oklahoma Trusts with multiple people. That was told to me when it was completed by the attorney, however, they had accepted several with no issues before mine was set up. You can rest assured that I'll re-post when I learn more.
 
Re: Notice from Trust Attorney for Sparrow Can....

<div class="ubbcode-block"><div class="ubbcode-header">Originally Posted By: ok6.5</div><div class="ubbcode-body">The trust was setup by this attorney, specifically for the Sparrow. He has setup several hundred trusts for similar purposes and was highly recommended by Cold Hand Arms. They have an impeccable reputation locally. The attorney's name is on the trust and I assume since he's done so many of them, he's probably been notified by the BATF. I'm hoping that it's not specifically about mine, but rather concerning all future NFA trusts. Again, this is an advisory. It says what it says and I'll post more when I get even more specifics. Not sure what the 'smell' test is, since the attorney, the dealer and myself included have done things exactly as required. I have researched it enough to know that for a while. the ATF questioned Oklahoma Trusts with multiple people. That was told to me when it was completed by the attorney, however, they had accepted several with no issues before mine was set up. You can rest assured that I'll re-post when I learn more. </div></div>

The part that smells bad is the ATF would NOT contact an attorney about changes like this.

They don't keep tallies on who does trusts, how many or anything. They will post the regs/rules/laws when they are applicable its up to the Attorney to keep up to speed on this, that IS part of what you pay for.

The ATF hasn't advised anyone because of one reason. NO CHANGES HAVE HAPPENED and any changes in the future have no ETA.

I called today and was told that they wouldn't put out a notification to a lawyer unless that lawyer was also an SOT and then it would have been put out to all SOT's(dealer and manufacturers).

Something is off.
 
Re: Notice from Trust Attorney for Sparrow Can....

So what would be the purpose of me receiving this email from the attorney? I must be missing something. Does the ATF verify that a trust is valid? Does the one person you contacted at the ATF know what's going on in the entire organization or is it like all other government agencies and no the right hand doesn't know what the left hand is doing? I've posted information that's been given to me and I'm 62 years old with many years of very close contact with all branches of government and every level of law enforcement from city, county, state and federal. I've seen stranger things happen. I've told the FACTS of what's happened. I take the 'smell' test as an insinuation that something has been distorted. The facts are the facts. Now, what created those facts is what is in question. Maybe next time, I'll let everyone find out on their own and keep it to my self. There DOES have to be a first time for something to happen.
 
Re: Notice from Trust Attorney for Sparrow Can....

<div class="ubbcode-block"><div class="ubbcode-header">Originally Posted By: ok6.5</div><div class="ubbcode-body">So what would be the purpose of me receiving this email from the attorney? I must be missing something. Does the ATF verify that a trust is valid? Does the one person you contacted at the ATF know what's going on in the entire organization or is it like all other government agencies and no the right hand doesn't know what the left hand is doing? I've posted information that's been given to me and I'm 62 years old with many years of very close contact with all branches of government and every level of law enforcement from city, county, state and federal. I've seen stranger things happen. I've told the FACTS of what's happened. I take the 'smell' test as an insinuation that something has been distorted. The facts are the facts. Now, what created those facts is what is in question. Maybe next time, I'll let everyone find out on their own and keep it to my self. There DOES have to be a first time for something to happen. </div></div>

This is easy. Have your attorney send the notice he got from Branch Chief Edward Saavedra and then you post it here.
 
Re: Notice from Trust Attorney for Sparrow Can....

<div class="ubbcode-block"><div class="ubbcode-header">Originally Posted By: ok6.5</div><div class="ubbcode-body">The trust was setup by this attorney, specifically for the Sparrow. He has setup several hundred trusts for similar purposes and was highly recommended by Cold Hand Arms. They have an impeccable reputation locally. The attorney's name is on the trust and I assume since he's done so many of them, he's probably been notified by the BATF. I'm hoping that it's not specifically about mine, but rather concerning all future NFA trusts. Again, this is an advisory. It says what it says and I'll post more when I get even more specifics. Not sure what the 'smell' test is, since the attorney, the dealer and myself included have done things exactly as required. I have researched it enough to know that for a while. the ATF questioned Oklahoma Trusts with multiple people. That was told to me when it was completed by the attorney, however, they had accepted several with no issues before mine was set up. You can rest assured that I'll re-post when I learn more. </div></div>

Does OK have a requirement to send in fingerprints, pics, etc. with a trust? I don't believe it does. If it is required in OK, OK would stand alone in that requirement, there's really no reason to have a trust and you've been fleeced.

If your lawyer does not know this and is advising you to send all of that unrequired nonsense in, I'd not take any of his advice from this point on and seriously question any advice he has given me in the past.
 
Re: Notice from Trust Attorney for Sparrow Can....

<div class="ubbcode-block"><div class="ubbcode-header">Originally Posted By: cardboardkiller</div><div class="ubbcode-body"><div class="ubbcode-block"><div class="ubbcode-header">Originally Posted By: ok6.5</div><div class="ubbcode-body">The trust was setup by this attorney, specifically for the Sparrow. He has setup several hundred trusts for similar purposes and was highly recommended by Cold Hand Arms. They have an impeccable reputation locally. The attorney's name is on the trust and I assume since he's done so many of them, he's probably been notified by the BATF. I'm hoping that it's not specifically about mine, but rather concerning all future NFA trusts. Again, this is an advisory. It says what it says and I'll post more when I get even more specifics. Not sure what the 'smell' test is, since the attorney, the dealer and myself included have done things exactly as required. I have researched it enough to know that for a while. the ATF questioned Oklahoma Trusts with multiple people. That was told to me when it was completed by the attorney, however, they had accepted several with no issues before mine was set up. You can rest assured that I'll re-post when I learn more. </div></div>

Does OK have a requirement to send in fingerprints, pics, etc. with a trust? I don't believe it does. If it is required in OK, there's really no reason to have a trust.

If your lawyer does not know this and is advising you to send all of that unrequired nonsense in, I'd not take any of his advice from this point on and seriously question any advice he has given me in the past. </div></div>

Trusts may soon have the requirement for prints and pics of all members of the Trust/LLC/Corp.

That is what I believe this is in reference to, the changing requirements if they are ever put into affect.
 
Re: Notice from Trust Attorney for Sparrow Can....

<div class="ubbcode-block"><div class="ubbcode-header">Originally Posted By: StalkingRhino</div><div class="ubbcode-body"><div class="ubbcode-block"><div class="ubbcode-header">Originally Posted By: cardboardkiller</div><div class="ubbcode-body"><div class="ubbcode-block"><div class="ubbcode-header">Originally Posted By: ok6.5</div><div class="ubbcode-body">The trust was setup by this attorney, specifically for the Sparrow. He has setup several hundred trusts for similar purposes and was highly recommended by Cold Hand Arms. They have an impeccable reputation locally. The attorney's name is on the trust and I assume since he's done so many of them, he's probably been notified by the BATF. I'm hoping that it's not specifically about mine, but rather concerning all future NFA trusts. Again, this is an advisory. It says what it says and I'll post more when I get even more specifics. Not sure what the 'smell' test is, since the attorney, the dealer and myself included have done things exactly as required. I have researched it enough to know that for a while. the ATF questioned Oklahoma Trusts with multiple people. That was told to me when it was completed by the attorney, however, they had accepted several with no issues before mine was set up. You can rest assured that I'll re-post when I learn more. </div></div>

Does OK have a requirement to send in fingerprints, pics, etc. with a trust? I don't believe it does. If it is required in OK, there's really no reason to have a trust.

If your lawyer does not know this and is advising you to send all of that unrequired nonsense in, I'd not take any of his advice from this point on and seriously question any advice he has given me in the past. </div></div>

Trusts may soon have the requirement for prints and pics of all members of the Trust/LLC/Corp.

That is what I believe this is in reference to, the changing requirements if they are ever put into affect. </div></div>

The OP stated in his original post that he mailed fingerprints, photos, etc. in with his Form 4 and trust paperwork. That is what I was addressing.

I'm not new to the NFA game. The whole changing the rules about trusts stuff has been around for years.
 
Re: Notice from Trust Attorney for Sparrow Can....

<div class="ubbcode-block"><div class="ubbcode-header">Originally Posted By: cardboardkiller</div><div class="ubbcode-body"><div class="ubbcode-block"><div class="ubbcode-header">Originally Posted By: StalkingRhino</div><div class="ubbcode-body"><div class="ubbcode-block"><div class="ubbcode-header">Originally Posted By: cardboardkiller</div><div class="ubbcode-body"><div class="ubbcode-block"><div class="ubbcode-header">Originally Posted By: ok6.5</div><div class="ubbcode-body">The trust was setup by this attorney, specifically for the Sparrow. He has setup several hundred trusts for similar purposes and was highly recommended by Cold Hand Arms. They have an impeccable reputation locally. The attorney's name is on the trust and I assume since he's done so many of them, he's probably been notified by the BATF. I'm hoping that it's not specifically about mine, but rather concerning all future NFA trusts. Again, this is an advisory. It says what it says and I'll post more when I get even more specifics. Not sure what the 'smell' test is, since the attorney, the dealer and myself included have done things exactly as required. I have researched it enough to know that for a while. the ATF questioned Oklahoma Trusts with multiple people. That was told to me when it was completed by the attorney, however, they had accepted several with no issues before mine was set up. You can rest assured that I'll re-post when I learn more. </div></div>

Does OK have a requirement to send in fingerprints, pics, etc. with a trust? I don't believe it does. If it is required in OK, there's really no reason to have a trust.

If your lawyer does not know this and is advising you to send all of that unrequired nonsense in, I'd not take any of his advice from this point on and seriously question any advice he has given me in the past. </div></div>

Trusts may soon have the requirement for prints and pics of all members of the Trust/LLC/Corp.

That is what I believe this is in reference to, the changing requirements if they are ever put into affect. </div></div>

The OP stated in his original post that he mailed fingerprints, photos, etc. in with his Form 4 and trust paperwork. That is what I was addressing.

I'm not new to the NFA game. The whole changing the rules about trusts stuff has been around for years. </div></div>

Missed that part.
 
Re: Notice from Trust Attorney for Sparrow Can....

I just sent out my paperwork (I did by LLC) but I did read the regulations about sending it in via trust and it states that you don't need a photo or fingerprints. Why was this sent to your attorney?
 
Re: Notice from Trust Attorney for Sparrow Can....

<div class="ubbcode-block"><div class="ubbcode-header">Originally Posted By: StalkingRhino</div><div class="ubbcode-body">
Missed that part.</div></div>

I had to go back and read the OP a couple of times and that part is a huge red flag that smells like yesterday's catch.

I don't get it.
 
Re: Notice from Trust Attorney for Sparrow Can....

...wait a second, is your trust attourney also a wealthy prince of africa.?

All joking aside, too many things seem very off.
-ATF "allegedly" contacted your lawyer
-photos and prints sent with a trust
-a trust only created for 1 specific can

Sounds more like a form 4 to a INDIVIDUAL, confused with a trust. Or vice versa

Here is what i'd do:
Call ATF with your information and verify that its a transfer to a trust vs an individual. Secondly ask what the current status is:
If denied: ask why, post reason here, fire your lawyer.
If approved: ignore the lawyer, talk to the dealer, enjoy your can
If problem status: get the details of why and ask atf how to rectify the issue, then talk about it with your dealer; contact the lawyer last.
If pending: wait two more weeks and call back

**disclaimer: I am not a lawyer, the above information is what I personally would do , none of this material is intended to be legal advice. use this information at your own risk. ***
 
Re: Notice from Trust Attorney for Sparrow Can....

I was pretty certain it was not the job of the ATF to decide what trusts are valid or not, only to make note that you have one. In that sense I thought it a no brainer that they would stay out of the realm of fingerprinting and CLEO signatures, like they do with individuals, and let only the courts deal with trusts. Of course it is the ATF so who knows.
 
Re: Notice from Trust Attorney for Sparrow Can....

<div class="ubbcode-block"><div class="ubbcode-header">Originally Posted By: MisterFistHer</div><div class="ubbcode-body">I was pretty certain it was not the job of the ATF to decide what trusts are valid or not, only to make note that you have one. In that sense I thought it a no brainer that they would stay out of the realm of fingerprinting and CLEO signatures, like they do with individuals, and let only the courts deal with trusts. Of course it is the ATF so who knows. </div></div>

Yes it is part of the job. They have to make sure it is valid for NFA Ownership and valid according to your State laws.

They are ADDING to the Trust/LLC/Corp requirements in the future(who knows when), fingerprinting of all members and mugshots of all members in the Trust.

There has been abuse with Trusts/LLC/Corps and it is also part of the horse trading going on with getting rid of the CLEO for individuals.

The ATF has no idea at this point if anyone in the Trust/LLC/Corp is a felon or otherwise prohibited individual.....that is what is being fixed, if it ever finalizes and goes into effect then they WILL know.
 
Re: Notice from Trust Attorney for Sparrow Can....

My can was just approved on January 26th... with a trust. I just spoke with the ATF about your exact situation... and the ATF agent who was extremely nice said and I quote "Your attorney is full of crap." Lol...
 
Re: Notice from Trust Attorney for Sparrow Can....

<div class="ubbcode-block"><div class="ubbcode-header">Originally Posted By: StalkingRhino</div><div class="ubbcode-body"><div class="ubbcode-block"><div class="ubbcode-header">Originally Posted By: MisterFistHer</div><div class="ubbcode-body">I was pretty certain it was not the job of the ATF to decide what trusts are valid or not, only to make note that you have one. In that sense I thought it a no brainer that they would stay out of the realm of fingerprinting and CLEO signatures, like they do with individuals, and let only the courts deal with trusts. Of course it is the ATF so who knows. </div></div>

Yes it is part of the job. They have to make sure it is valid for NFA Ownership and valid according to your State laws.

They are ADDING to the Trust/LLC/Corp requirements in the future(who knows when), fingerprinting of all members and mugshots of all members in the Trust.

There has been abuse with Trusts/LLC/Corps and it is also part of the horse trading going on with getting rid of the CLEO for individuals.

The ATF has no idea at this point if anyone in the Trust/LLC/Corp is a felon or otherwise prohibited individual.....that is what is being fixed, if it ever finalizes and goes into effect then they WILL know. </div></div>

Geez! How much of a cluster would that be if they did this retroactive on ALL the trusts. It would take years to get a Form 1 or 4 through with all their resources tied up trying to get caught up.
 
Re: Notice from Trust Attorney for Sparrow Can....

<div class="ubbcode-block"><div class="ubbcode-header">Originally Posted By: MisterFistHer</div><div class="ubbcode-body"><div class="ubbcode-block"><div class="ubbcode-header">Originally Posted By: StalkingRhino</div><div class="ubbcode-body"><div class="ubbcode-block"><div class="ubbcode-header">Originally Posted By: MisterFistHer</div><div class="ubbcode-body">I was pretty certain it was not the job of the ATF to decide what trusts are valid or not, only to make note that you have one. In that sense I thought it a no brainer that they would stay out of the realm of fingerprinting and CLEO signatures, like they do with individuals, and let only the courts deal with trusts. Of course it is the ATF so who knows. </div></div>

Yes it is part of the job. They have to make sure it is valid for NFA Ownership and valid according to your State laws.

They are ADDING to the Trust/LLC/Corp requirements in the future(who knows when), fingerprinting of all members and mugshots of all members in the Trust.

There has been abuse with Trusts/LLC/Corps and it is also part of the horse trading going on with getting rid of the CLEO for individuals.

The ATF has no idea at this point if anyone in the Trust/LLC/Corp is a felon or otherwise prohibited individual.....that is what is being fixed, if it ever finalizes and goes into effect then they WILL know. </div></div>

Geez! How much of a cluster would that be if they did this retroactive on ALL the trusts. It would take years to get a Form 1 or 4 through with all their resources tied up trying to get caught up. </div></div>

Would be grandfathered. Any NEW applications would have to follow the new regs/rules/laws etc.
 
Re: Notice from Trust Attorney for Sparrow Can....

Sorry, but I may have inadvertantly added to some of the confustion. Originally, when I paid for the Sparrow, I was going to do it as an idividual. I got the pics, prints etc ready to send in. I was informed about the ability to do it as a trust, even though I had done the prints and pics. I then went to the NFA trust attorney who has done hundreds of these. Although it delayed the filing a bit, the benefits were obvious. I then went back to the dealer with the new trust paperwork and completed the paperwork. I submitted the application and may have sent the prints and pics needlessly. The fact still remains that the attorney's assistant did send the advisory to me with the above information. Since this is my first NFA trust, (and I'm over 60) my memeory as to what I needed to send in might not have been clear. I have requested a copy of the 'advisory' and whether it was specific to my application or a general advisory. As soon as I receive it, I'll make the post and a copy of what I receive. Thank you for the comments, but it does appear that at least some have also heard of the possible future request for all memembers of a trust. I do remember asking about 'why' the trust circumvented the need for the prints and pics. I also couldn't see how they would know if the people in the trust were felons or not. I look forward to clarifying the 'advisory' and to whom it was directed as soon as I receive it.
 
Re: Notice from Trust Attorney for Sparrow Can....

Could the notification come from NFATCA? They send out a newsletter with NFA news.

As others have mentioned, there was a "comment period" on a rule making which dealt with fingerprints and photos for trusts. LINK


 
Re: Notice from Trust Attorney for Sparrow Can....

As I said I would do, here is the response from my NFA Trust attorney. His intent with the advisory was to keep his clients informed with 'possible' future changes based on current proposals. In this case, he's concerned about adding anyone else to the trust if the proposed changes are approved. Here's his response to my email:

Tom: The NFA Trust advisory is something I sent out to my clients giving them a heads up. There is no specific notice from the BATF, although the proposed rules are available. I would not expect the rules to affect your pending application, but could on a going forward basis, such as adding trustees.


Since he's an avid shooter and has taught his children how to hunt safely, his concern was to keep his clients informed as to possible future changes. Sounds more like an FYI.
 
Re: Notice from Trust Attorney for Sparrow Can....

Yeah that it does. I can definitely see it happening in the future but nothing will happen any time soon. There is more attention being paid to other firearm legislation. That is until some unstable asshole shoots some place up with a silenced AR-15, then silencers will be thrown in with the other "death machines."
 
Re: Notice from Trust Attorney for Sparrow Can....

Well, I guess that clears up the confusion. See why it wasn't passing the smell test now?
 
Re: Notice from Trust Attorney for Sparrow Can....

always wondered about this...never made sense to me why the NFA wouldn't want to do background checks on everyone that was going to be on the trust.
 
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