ATF 41F is going into effect on Wednesday, July 13, 2016.
In A Nutshell, Here’s What 41F Means To You:
41F will require the applicant(s) to attach the following items to their application:
All applications “postmarked” (i.e., submitted) before July 13, 2016, WILL NOT be affected by the rule change, as it will not be retroactive.
41F is set to be implemented on July 13, 2016.
You and any Co-Trustees on the Trust will be required when submitting a tax stamp application to notify the chief law enforcement officer (CLEO), but WILL NOT require their “approval.” (This “requires that a copy of all applications to make or transfer a firearm, and the specified form for responsible persons, as applicable, be forwarded to the CLEO of the locality in which the applicant/transferee or responsible person is located; and eliminates the requirement for a certification signed by the CLEO.”)
Beneficiaries WILL NOT be considered responsible persons (i.e., beneficiaries will not have to do anything when a Form 4 is submitted).
You DO NOT need to notify the ATF when adding a Co-Trust to the Trust.
A completed ATF Form 5320.23 for each responsible person will also need to be included in an NFA registration after 41F takes effect. Form 5320.23 would require certain identifying information for each responsible person, including:
Each responsible person’s full name, position, home address, date/place of birth, country of citizenship, and Social Security number (optional);
A 2×2-inch passport-style photograph of each responsible person taken within one year prior to the date of the application;
Two properly completed FBI Forms FD-258 (fingerprint card) for each responsible person.