41P signed and passed

[SouthPaw]

Well the party ends in 180 days from today. Great way to start 2016.

https://www.atf.gov/file/100896/download

[Brian]

Assuming I'm reading this right on my first pass of the summary pages:


1) Responsible person(s) now required, including fingerprints and photographs
2) CLEO signature removed
3) CLEO notification required
4) Adjust treatment of estates. If you die, your executor can possess your junk without "transferring" it to them, and transfer to a beneficiary is tax-exempt
5) Valid 180 days from date published
6) 5330.20 not required going forward as it'll continue to be absorbed in other forms


248 pages of comments and propsed amendments, etc.

[kwando]

Is it too late to submit forms tonight? Fuck!

[Roger Ronas]

Assuming I'm reading this right on my first pass of the summary pages:


1) Responsible person(s) now required, including fingerprints and photographs
2) CLEO signature removed
3) CLEO notification required
4) Adjust treatment of estates. If you die, your executor can possess your junk without "transferring" it to them, and transfer to a beneficiary is tax-exempt
5) Valid 180 days from date published
6) 5330.20 not required going forward as it'll continue to be absorbed in other forms


248 pages of comments and propsed amendments, etc.

so am I reading your notes correctly, No CLEO sig Needed?
How do you notify CLEO?

Also my questions:
Do we have 180 days to get trust and any forms filed before this takes affect?
Is today the published date so that means 7-3-16 a valid date?

May be Rodney will chime in

Roger

[SouthPaw]

Trusts never need a CLEO signature to begin with. I think someone pointed out that individual forms will no longer require CLEO signature only notification.

This means I am going to start having to miss work to get fingerprints done along with my family members as well to abide. Ridiculous.

[brutal]

Many thanks to the National Firearms Act Trade and Collectors Association for fucking this one up.

My understanding is they tried to work their way around CLEO's not signing off on individual NFA submissions by changing the process. Then we ended up with 41P. My reading of this in its current state is that CLEO sign off is not required for trusts, but fingerprints and photo, NICS, and CLEO notification after form1 maker or form4 transfer approval is required.

What happened to removing suppressors from NFA? Wasn't that supposed to be the trade off for this horseshit?

[Dave_L]

Well bunch of horse crap. Would like to get some more clarification on this. Do we have time to submit more before it goes into effect? So now with trusts, I still have to get fingerprinted and photographed for EVERY item?

[Brian]

Trusts never need a CLEO signature to begin with. I think someone pointed out that individual forms will no longer require CLEO signature only notification.

This means I am going to start having to miss work to get fingerprints done along with my family members as well to abide. Ridiculous.

True, but "responsible person" CLEO signoff for trusts were part of the original draft, which was what I was trying to say.

[DangerLee_Industries]

It reads that this goes into enforcement in 180 days from today. I am not a lawyer and don't work for the ATF but that's how I read it.

[Brian]

Well bunch of horse crap. Would like to get some more clarification on this. Do we have time to submit more before it goes into effect? So now with trusts, I still have to get fingerprinted and photographed for EVERY item?

Yes, at least 180 days until it takes effect. Make sure you're in pending and you're probably 90% sure you're grandfathered. Might be ok if you mail your form by then too, but I wouldn't risk it.
Yes, you will need to get fingerprinted/photographed/notification for every form (every item) starting 180+ days from now.

Figure some suppressors will sell out this week, and ATF lead times are going to lengthen due to the influx of expected forms starting tomorrow morning.