I don't really have any links to the info as it all came through direct conversation with the attorneys. I can tell you that the firearms attorneys all said that the name of the trust does not matter with one caveat from the firearms law specialists. They said to make sure that you do not include anything in the name of the Trust that makes reference to the NFA or ATF and that the name making reference to firearms in any way was also not recommended. The rational for this had to do with the theory that ATF could, at some point decide (or be told to decide) that Trusts like this that are done to avoid having a CLEO signoff violate the "spirit" of the exemption and could be voided. The firearms attorneys cited something similar that happened in the early '90s as an example of the possibility but I honestly can't remember the example now.
The attorney also said that they had several clients who insisted on putting some type of NFA or firearm reference in the Trust name have their paperwork rejected by ATF. When ATF was questioned by the attorneys, this reference was cited as the reason for denial. Interestingly enough she did tell me that for every Trust they had rejected like this, they had another go through. What can you say, the ATF is the ATF. They now just make sure there are no references in the Trust name just for safety's sake. Conversely, you can have references to the NFA and firearms all through the Trust document itself as it is only the name that seems to cause problems.
The use of a special Trust bank account to make purchases is one more CYA from the attorneys. Mine did say that if I absolutely had to pay cash for something to make sure that all of the sale documentation lists the Trust as the buyer. Referencing a Trustee's name as acting as the representative of the Trust is OK as long as the way it is written leaves no doubt that the Trust is the purchaser. My attorney also said it would be best if I could show a withdrawal from my Trust's bank account for the cash before the date the purchase occurred.
All of this is just an attempt to avoid any semblence of impropriety in your actions or records in the rare instance that the ATF decides to take a closer look at something you have, or they think you have, done. I have also talked these issues over with a friend's wife who is an FBI Special Agent who has done some joint task force work with the ATF. Her comment was that while the ATF examiners she had worked with seemed to be good people, some of the ATF investigators were "a little overzealous".
Take all of this in whatever way you wish. Considering how much money I have/will have invested in NFA items, I personally will do whatever the experts tell me to do so that I can avoid any issues with the ATF.
As to the FFL, it did not involve a Trust. He is a regular Class 1 dealer. As I understand it, he sold several guns (I think it was between 10-15) to a "security company" based on responding to a request for bid that they provided him. Unfortunately the "security company" didn't exist even though everything looked legit and they paid with a company check which cleared just fine. Long story short, the guns ended up in the hands of some people they shouldn't have and the ATF basically accused him of knowingly making a straw man sale in quantity. I just used this as an example of the kind of hell that ATF can put you through if they think you have done something wrong.
Let me know if there are any others questions I can answer.
Stay safe over there.





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