I am not sure what the “did this” you are referring to is, and also not sure if you are trying to sound condescending, but there really isn’t a way that it wasted any money.
Aside from that, a person “named in the trust” as NOT a trustee during my lifetime is NOT a responsible party today. There are millions of people who could be named in the trust next week, but the as submitted version of the trust is what is supposed to be reviewed. That being said, if the way it is worded is on legal shaky ground as stated, no one has read it in a decade because many approvals have occurred. If the examiner saw an ambiguity they of course they asked the ATFs counsel and who would like to guess they recommended.
For anyone tracking the outcome of this, I had a long talk with a very nice “Legal Instruments Examiner, US DOJ, BATFE NFA division - Industry Processing Branch” phew that’s a mouthful today they said once the issue of wording is remanded to ATF counsel that the resolution is essentially binding. I drafted an amendment to the trust striking everyone’s name except the names responsible parties, named myself as the only lifetime beneficiary and emailed it to them with the understanding I would shred it immediately afterwards and the trust would revert back to its original language. They said that was perfectly acceptable that the Form 4 would now be approved. They also reminded me to not forget to add this amendment for each future submission again with the understanding it only needed to be in place at the time of submission not through the entire approval process.
it is all a bit silly, but it is what it is. I thought this post would serve as a PSA for people to be on the lookout, but it if has outlived its purpose, please lock it. Thanks.
