Can't find an answer about 41f

[Shagnasty]

So I have a trust currently holding an NFA item.

If I add more items AFTER the July 13th effective date, do I have to submit "responsible person" forms for those who were on my trust PRIOR to that date? or am I grandfathered?

Basically, will adding new items in the future mean my trust will be held to the new standard, even though it was used/approved before the new rules?

[punkey71]

According to SS it sounds like you'll have to submit responsible person forms after July 13th, regardless. I'm sure many folks have opinions or interpretations but I'm guessing SS is pretty on top of the changes.

It seems there are some questions out there due to poorly written laws/regs (weird, I know) but submitting prints and photos for responsible persons is pretty much a done-deal.

http://blog.silencershop.com/details-atf-41f/

But who knows...anything could be changed, I guess.

Im a pessimist though. I will be done with SBRs and can submissions by June.


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[BigWaylon]

There's no "grandfathering" of any kind with legal entities. Any submission on/after 7/13/16 will have to meet the current rules. Doesn't matter if the trust/corp was started on the 12th, or the 13th...or 25 years ago. Doesn't matter if that trust has 100 stamps, or it's the first. Nothing matters but the date of the submission, and the current responsible persons at that moment.

For an entity, every responsible person will submit a 5320.23 along with prints and photos...for every submission. There is a 24-month window for the trust/corp documents themselves. If you have an approved form within the last 24 months, you will simply certify that the docs haven't changed since the last approval. Unlike some of the early reports/interpretations suggested, there is not a 24-month window for the prints and photos.

[SC-Texas]

Yes. Fingerprints and photos for forms submitted after July 13.

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[SC-Texas]

https://youtu.be/FWxEO882144

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