So I bought a machinegun from an individual who is going to transfer it to my dealer. He said that he's done them before, but the dealer filled out the Form 4 and he just signed it and sent it in along with the $200. There's no rule on who has to fill out the forms and my dealer hasn't received a Form 4 transfer from an individual before, so I figured I'd give it a try. Everything on the Form 4 seems pretty straight forward, but I ran in to a couple of questions. The dealer's company is an LLC. Questions (18) and (19) asks for the number of responsible persons and the full name of each responsible person. According to the definition of responsible person (1)(e), the owner is an obvious responsible person, but it gets vague from there. The other people involved are the lady that does all of the NFA paperwork and other regular employees. The definition says "any individual who possesses, directly or indirectly, the power or authority to direct the management and policies of the trust or entity to receive, possess, ship, transport, deliver, transfer or otherwise dispose of a firearm for, or on behalf of, the trust or legal entity." Since everyone who works there can do transfers, it would technically include everyone as a responsible person. However, that doesn't seem logical to me. So is it just the owner and those directly involved in the paperwork for NFA transfers or is it literally every employee that works there?
For question (13) Transferee Necessity Statement, what should a dealer receiving from an individual put? The instructions simply say that it must be completed. The Name and Title of the transferee has to be listed. Is this the name of the owner or the business name of the LLC? What is the reason to put?
https://www.atf.gov/file/61546/download
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