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All responsible parties of a trust will now be required to submit fingerprint cards, photos, and a new questionnaire form with Form 1 and 4 applications.
The Chief Law Enforcement Sign Off has been REMOVED from ALL applications, both trusts and individuals.
HOWEVER, you will be required to forward a copy of the completed (by you prior to sending it to the ATF) Form 1, 4, or new 5320.23 Responsible Person form to the Chief Law Enforcement officer in that person's locality.

So, No more CLEO sign offs, but you have to provide your CLEO a copy of the form prior to sending it off to the BATFE. In addition, EVERYONE has to send in pictures, prints, and for trusts, a responsible person info sheet for everyone on the trust.

This ruling does not go in to effect for 180 days. Roughly around the 4th of July. All Forms POSTMARKED prior to the effective date will be processed under the current rules.

http://www.thetruthaboutguns.com/20...es-fingerprints-but-eliminates-cleo-sign-off/

https://nlolegal.wordpress.com/2016...to-know-about-atf-rule-41f-formerly-rule-41p/
 
I wonder if they will start accepting electronic submissions from non-trusts now? Not sure how that works with the fingerprint card. Seems like they will have to either do away with electronic submission or have some way that you can send in the paperwork after submitting the electronic form.
 
In a perfect world there would be no NFA, but given that there is, this seems a reasonable compromise, don't you think? I.E., that the BATF knows all parties to the trust, and that trusts then don't need a CLEO signoff?
 
So does this mean when I have a trust, then add people later I just resubmit the paperwork with anyone new added?

Anytime I add another member I must go through the fingerprint and ID stuff with them and the ATF.
 
I don't think it's the apocolyptic ruling that people seem to be making it out to be. Does it make things a little more of a pain in the bubblegum? Yes. Does it open the door for people who were screwed by their CLEO? Yes to that as well. I do see some issues arising from it as far as implementation and records however.
 
So does this mean when I have a trust, then add people later I just resubmit the paperwork with anyone new added?

Anytime I add another member I must go through the fingerprint and ID stuff with them and the ATF.

I don't believe that's addressed in the ruling. As it stands the ruling only talks about when you file the Form 1 or 4. If BATFE doesn't clarify this then it's only during the application process seemingly.
 

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