500 trusts approved by ATF.
If you name trustees in the body trust, they are responsible parties under the body of the trust and have to be printed, photographed, and sign for each Form 1 or 4 application. This is cumbersome and time consuming. We have existing trusts where the whole family comes down for a sign, pic and print party.
Your named successor grantors, so if the original grantor dies, the trust automatically transfers to the named successor. Basic succession planning, but the successor grantor is not a responsible party until such time that you die, and then, as long as they are legally able to possess the inventory of the trust, they are only then the responsible party. Trustees added by addendum, after the formation of the trust are specifically not listed as responsible and controlling parties of the trust assets. Trustees can be added or removed at any time, but cannot control trust assets.
NFA only requires one copy of the trust with each application, or multiple applications made at the same time. I'm submitting 3 suppressors for one client today, with that I'll sub (2) photos, (2) fingerprint cards and (1) trust copy. You do not need to send multiple trust copies, the ONLY exception to that is if you submit a form 1 AND form 4 TOGETHER. Those are divided and processed separately at the NFA branch, generally they apply all the pics, prints, and trust copy to the form 1, leaving the Form 4 naked, then they'll send you or me a correction notice. (Little known fact...they scan these documents, if they have a form 1 approved or in process, the people requesting the pics and prints can actually look up the trust name, and pull the print cards and pics from the other file).
Most noteworthy thing to mention here. The people at the ATF branch are really nice, but make a lot of mistakes. The mail service at the Atlanta receiving deport AND at the Martinsburg WV lose a healthy amount of documents. The NFA branch misfiles even more. They will ask for things they already have. They will ask you to change data that is hard fact. Case in points, from this week ALREADY:
#1) My favorite. I get a couple a week on this one. "Our data indicates the suppressor is 7.75" in length, not 7.09". My response, "As you can see from then attached photo, the suppressor is actually 7.09" as indicated by the ruler in the photo. I tried to stretch it to 7.75 but these things are pretty tough. I've included a corrected form and the original, you decide whether your data or the ruler is correct and discard the other document". So I started sending them in as 7.75" after a couple dozen times, I'll play their game. Now I get corrections back that the suppressor is 7.09". How do you win? The best one, same client bought 3 identical cans, 2 approved at 7.09" and one returned for correction to be 7.75. Seriously, its laughable most of the time.
#2) They request page 2 of Form 4 be corrected, so I send it to them. They reply and say no, they need the RPQ document. We've sent them the RPQ already. Why did you send me page 2 of the form 4 if you wanted the RPQ? They request a copy of the Responsible Party document to be completed. OK, I comply and send it again. They've told the client once that his forms have been approved, he calls and is asking to pick up...I tell him that we call clients on approvals the same day, as soon as we have them, we call you.
#3) We get a correction notice, pics and prints are missing. This was a form 1 and form 4 application where we supplied multiples for different form types. So we send another set to them, 4 weeks ago. They call my client Monday (not me, but the client) and tell him that they are going to deny his application because the information is missing...he panics. My phone blows up. I call and email the examiner. She calls back Tuesday, say his forms are approved. Yeah, done. Right? Nope. Her assistant calls back Wednesday and says we need pics and prints still, the forms aren't approved. I inform her that we've supplied 3 sets, isn't that enough? How many times do you need to lose these documents, but ok...sure. I ask her, hey, you approved his form 1's on November...can you look that up? "Of course, yeah,. same trust name?" She looks it up, his prints and pics were scanned in 3 times, to his form 1, they never routed them into his form 4 folder. OK, so were good right? "Yes sir, we're all good to go.". Whew, had enough yet? I get a call back an hour later, we need his pic still. OK, can I email it? "yes sir". OK, I open his trust file, email his photo to her and were done. This morning, I called and they told me unequivocally, the suppressor stamps are now APPROVED. I wonder what tomorrow will bring.
#4) Client calls. Says she's waiting on her trust for 9 months.
me: Um, no we did your trust 9 months ago, you're waiting on a stamp.
her: "No, I got a letter saying I have 30 days to fix something."
me: OK, what does the letter say?
her: "It says I have 30 days to fix something, you need to fix this now".
me: Ma'am, I cant fix it if I don't know what it is I'm supposed to fix. What am I supposed to fix? Can you send me a picture of the letter or read it to me?
her: "You need to shut up and listen it needs to be fixed in 30 days".
me: OK, Ma'am, I remember your situation now. We did your trust and your husband is transferring his SBR into the trust name. He is the transferor and the Transforee. You completed that form and submitted it to ATF, not us. We did help you with it though.
her: "Stop talking and fix this now. They lost the documents and want me to refile. They have the wrong address on them"
me: OK, they lost the documents and told you that they lost the documents and want you to refile it. I got it. You'll need to send them a new form 4, I'll be happy to complete that form for you and mail it to you for signature, what is the address I should use?
her: "No, you need to send it to them. You need to call them and work this out."
me: Well, they wont talk to me because I'm neither the transferor or transferee. I can call, but they wont share that info with me. But heck I'll do it anyways,
her: "thank you, that's all I'm asking."
Me: OK, I'll call you back shortly.
Me: Ma'am I spoke with ATF, they wont share that info with me, they'll only do it with your husband. But I want to help, so can you send me any information you have from ATF.
her: "click".
OK...that went well. ATF had the wrong mailing address for the people. They mailed a correction notice with the original form 4 application to the old address on the original form 4, they didn't receive that one. They mailed another correction document to their current address, they received that one, but the original forms are now missing.
Moral to the story?: NFA branch is full of nice people. Many are contractors and job security is established by not moving the needle. They must have motivational signs around the building "Be pleasant, but don't be fast". "Be mostly accurate, yet incomplete". You will get different answers, different days.
Thanks for weighing in on the conversation! You folks have my application, just waiting to get the call to come in and finalize it! Can't wait!
