Don't know how many people are using trusts or corporations for their Title 2 / NFA items, but I wanted to make everyone aware of some proposed changes to the process.
I'm sure most of you have heard of the CLEO sign off for individuals going away potentially. Well, that's good news, but what I didn't realize until today is that the main purpose (title) of the proposed change is to require <span style="font-weight: bold">each</span> responsible member of a trust of corporation to submit fingerprint cards and photographs. This new regulation hasn't been adopted yet, but supposedly it's in the stage of "proposed rule making" so it may only be a matter of time.
<span style="font-style: italic">he Department of Justice is proposing to amend the regulations of the Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) regarding the making or transferring of a firearm under the National Firearms Act. The proposed regulations would (1) add a definition for the term "responsible person"; (2) <span style="font-weight: bold">require each responsible person of a corporation, trust or legal entity to complete a specified form, and to submit photographs and fingerprints</span>;</span>
http://www.reginfo.gov/public/do/eAgendaViewRule?pubId=201210&RIN=1140-AA43
This should be a huge strike against the trust/corporate route and would add time and complexity. I would imagine processing times going up as the rate of paperwork errors should increase when everyone has to submit additional documentation.
Does anyone have more information? This seems to be sneaking under the radar compared to all the AWB talk. I've had some items I've been meaning to Form 1, and I'm going to do so within the next few weeks so I don't have to deal with these new potential requirements.
I'm sure most of you have heard of the CLEO sign off for individuals going away potentially. Well, that's good news, but what I didn't realize until today is that the main purpose (title) of the proposed change is to require <span style="font-weight: bold">each</span> responsible member of a trust of corporation to submit fingerprint cards and photographs. This new regulation hasn't been adopted yet, but supposedly it's in the stage of "proposed rule making" so it may only be a matter of time.
<span style="font-style: italic">he Department of Justice is proposing to amend the regulations of the Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) regarding the making or transferring of a firearm under the National Firearms Act. The proposed regulations would (1) add a definition for the term "responsible person"; (2) <span style="font-weight: bold">require each responsible person of a corporation, trust or legal entity to complete a specified form, and to submit photographs and fingerprints</span>;</span>
http://www.reginfo.gov/public/do/eAgendaViewRule?pubId=201210&RIN=1140-AA43
This should be a huge strike against the trust/corporate route and would add time and complexity. I would imagine processing times going up as the rate of paperwork errors should increase when everyone has to submit additional documentation.
Does anyone have more information? This seems to be sneaking under the radar compared to all the AWB talk. I've had some items I've been meaning to Form 1, and I'm going to do so within the next few weeks so I don't have to deal with these new potential requirements.