Saw this memo posted on the saiga 12 forum. I don't know what NPRM means, but it looks to be instituted around July of 2013. They're removing the CLEO sign-off, now you'd have to notify the CLEO (applies to everyone: trusts, LLC's and individuals). They're also making it so every person listed on the trust/LLC has to submit passport photos and fingerprints. I don't know how this would affect adding and removing people, it'll probably be a part of the "specified form."