Address change and CLEO notification questions?

[Hummer]

My FFL submitted my form 4, tax, and copies of my trust last July prior to 41P. Who knows, but approval might take another 6 months to a year or more. We plan to move full time from our primary residence in county M to a secondary residence in county B, but we'll maintain and visit both homes. While my wife will make a change of address for mail and driver's license within the 30 days required by Colorado, I don't think I necessarily need to do so if I continue to claim my primary residence (and receive mail) in county M.

What if any, are the implications of an in-state address change before the paperwork is approved? Although the BATFE isn't concerned about in-state address changes for possession of suppressors after registration, is it a concern prior to the issuance of the stamp? If I were to change my primary residence before taking possession, am I required to notify BATFE and if so, what is the appropriate time and method for that? Should I keep it simple and wait to officially/legally change my address?

Also, under the new regulations, how is CLEO notification to be made? What form and at what time in the process would I provide notification to either county Sheriff M or county Sheriff B? From this section it seems this would have been submitted at the time my application was submitted--but that doesn't make sense to me. https://www.atf.gov/firearms/qa/chief-law-enforcement-officer-required-sign-law-enforcement-certification-atf-form-1-or

"....the final rule....
amends the regulations to eliminate the requirement for a certification signed by a CLEO and instead adds a CLEO notification requirement. Prior to submission of the application to the Director, all applicants/transferees and responsible persons shall forward a completed copy of ATF Form 1 or ATF Form 4, or a completed copy of Form 5320.23, respectively, to the chief law enforcement officer of the locality in which the applicant or responsible person is located. The chief law enforcement officer is the local chief of police, county sheriff, head of the State police, State or local district attorney or prosecutor. If the transferee is not a licensed manufacturer, importer, or dealer qualified under this part and is a partnership, company, association, or corporation, for purposes of this section, it is considered located at its principal office or principal place of business; if the applicant/transferee is not a licensed manufacturer, importer, or dealer qualified under this part and is a trust, for purposes of this section, it is considered located at the primary location at which the firearm will be maintained."


How does this actually work now? If I notify sheriff M while still officially residing here, must I also then notify sheriff B once I effect a change of address? I don't see any language that covers that.

Those of you who have received your stamps since July 13, how did you handle notification?

[Circuits]

Tax stamps are not forwarded automatically - they're returned to ATF with notification of your new address (result of the "Return Service Requested" on the envelope). ATF will then either send it out to the new address separately and at a later date, or contact you there to get you to submit an address correction.

CLEO notification was made when you applied, to the CLEO where you resided when you submitted the application. No notification to new sheriff is required for such an instate move.

[Great-Kazoo]

Tax stamps are not forwarded automatically - they're returned to ATF with notification of your new address (result of the "Return Service Requested" on the envelope). ATF will then either send it out to the new address separately and at a later date, or contact you there to get you to submit an address correction.

CLEO notification was made when you applied, to the CLEO where you resided when you submitted the application. No notification to new sheriff is required for such an instate move.

He submitted prior to 41P, shouldn't be any notification required. Never has been with my trust submissions

[SAnd]

The Form 4 is returned to the dealer. Contact your dealer and ask them how to handle it.

[Brian]

There's no issue, and you won't have a problem. :)

In your situation, there's no requirement to notify anyone when you move in-state. ATF requests notification, but does not require. You'd use federal form 5320.20 for that, if you wanted to for some reason.
One important, related (loaded) question - are you sure the trust is moving anyway?

In short though, by submitting pre-41f, you're grandfathered in and the new notification, etc. regulations don't apply to this purchase.

(Post-41p restrictions are different though, for anyone reading this at a later date...)

Hope that stamp comes in soon...

[Hummer]

Thanks for the comments re CLEO notification. I wondered if moving would create a bureaucratic delay with the feds, and if under the new regs I might somehow be obligated to comply with both pre- and post-41 CLEO notification requirements. Unable to find the information online I thought I'd pose the questions here. And I was curious how many different answers I would get. [Coffee] Being an NFA virgin I wasn't clear on how it all transpires.

[Circuits]

The Form 4 is returned to the dealer. Contact your dealer and ask them how to handle it.

Good point, I was thinking F1 for some reason - Form 4 indeed goes to the transferror (FFL), not the transferee.

[Hummer]

Thank, fellas! Since I have everyone's attention I'll throw out another Q or two. Since my paperwork went in shortly before the July 13 deadline and since there were likely 10K or more other submissions around that time, what's your best guess as to turnaround time on the stamp. 2019?

Any inside information on the actual number of apps in the queue? Has the BATFE increased staff to handle the increased workload?

[Circuits]

ATF was reporting 8 months plus, and has been approving forms submitted in February and March most recently. Given the jump in applications to beat 41F, a July submission will be no earlier than March next year, and possibly as long as a year (July 2017). Doubt it'll drag out until 2019.