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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."
 
Really wondering how this will effect my 2 stamps still in waiting on a Trust

don't get all giddy just yet, nor should you expect the July date as de facto. prior to the modification of the Code of Federal Regulations, a NPRM is needed. the citation posted above is a PRE-NPRM. if it gets past the PRE stage, then the NPRM is posted in the Federal Register for a period of time during which public commenting is elicited. barring any deal breakers, the CFR is modified.

even if the CLEO signoff is abolished, note that there are still many devils in the details. i am very cautious in my expectations. i had posted similar apprehensions on another forum. I view the current process as akin to freeway traffic being metered at the on-ramps.

currently, traffic (i.e. applications to Tech Branch) is brisk, with wait times now 8-12 months (previously 4 mos) with existing staff.

the metering was done at the local level. if the CLEO signoff is not attained (failed background check, failed state firearm litmus test) you don't pass GO. folks who persevere can sometimes circumvent the CLEO signoff by opting for the trust or corp route. these 'obstacles' inherently help control the traffic flow of applications to BATF.

let's say they remove the CLEO signoff. we can now send our applications direct to BATF. if their staffing isn't increased (already deficient in terms of handling the current load) it doesn't take much of a stretch to predict that the wait times will become even more exacerbated.

perhaps i'm overthinking this but it's akin to going back in time and trying to change history. we may have lobbied to void one of the big headaches in the NFA application process (CLEO signoff) but it remains to be seen how the victory will be measured. will we have, in effect, argued ourselves into a weaker position, or, just traded six problems for a half dozen others?

no real answers or anything conclusive. just fretting and not willing to declare true victory. with all that is going on with this President, congress, AWB II, etc, I foresee that they will just learn from their mistakes and become more emboldened, smarter, and will create new obstacles different than the traditional methods or that seen historically. for example, huge taxes on ammo, reloading supplies, etc.

sadly, the politics involving gun control is like a chess game.
 

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