With the implementation date of ATF 41F looming just around the corner (July 13, 2016), the folks over at ATF have released the ATF 41F FAQ. You can find that here. The link also includes the new Form 1, Form 4, Form 5 and Responsible Person Questionnaire.
The FAQ references:
- How Does Final Rule 41F Change Current NFA Regulations?
- Who is a Responsible Person?
- What Do NFA Trust or Legal Entity Applicants Affected by the Change Need to Know?
Earlier this week, The Gun Collective released a new series called, The Legal Brief, where I discussed ATF 41F and its implications. One of the questions that wasn’t quite clear was whether a legal entity would be required to submit a copy of the Form 1/4/5 and responsible person questionnaires to the CLEO or if it would be one or the other.
Based on the question in the FAQ, it would seem that legal entities, such as trusts, corporations, LLCs, etc. will need to submit a copy of the Form 1/4/5 to the CLEO for notification in addition to all of the responsible persons submitting the responsible person questionnaire.
ATF has also confirmed, as if there were any doubt at this point, if the application is postmarked July 12th or earlier, it will be grandfathered in under the current regulations. July 13th and after will require you to comply with ATF 41F.
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