Buying NFA under 41F. Now what? Transfer to your existing gun trust or to yourself as individual?

[Neo]

My gun trust is from Silencer Shop: http://www.silencershop.com/services/nfa-gun-trust.html
I have no trustees on my gun trust yet, so at least I wouldn't have to trouble anyone yet.

So I didn't buy everything I wanted before 41F and I have the itch to buy again. However, everything I have is under my gun trust and all items were secured before 41F. What happens if I transfer a new NFA item to my existing pre-41F trust? Does that negate any advantages I had of skipping the photos and fingerprints? Would it be as if all of my pre-41F items are now subjugated under the new 41F regulations, and the ATF will attach my prints and photos to my file/trust? If so, would there be any benefits to transferring items to myself as an individual instead of to my existing pre-41F gun trust? Perhaps filing new items as an individual would keep the two records separate (my trust and myself) and only having 41F records (photos + fingerprints) on myself for post 41F items?

My understanding is that CLEO notifications are mandatory under both paths. 

And what's with this 2 year thing. Do we have to send in new photos and fingerprints every 2 year to the ATF indefinitely, or only when we are buying new NFA items?

Anything else that I may be forgetting?

[johnsonlmg41]

If you transfer any items from your trust to you, you'll have to include FP cards and a photo.  Any new items added personally will require FP cards and a photo each time, so I'd look at that as a time saver.   Your info (cards and photo) will be associated   with your trust and any items within it already if they need to look you up for some reason?

Once you submit anything new to any trust post 41P it will require FP cards and a photo.   Anything bought for an additional 2 years after this submission will not require additional FP cards or a photo if put into the same trust.  If you decide in 2 years you're not getting anything else your info lapses and you are not required to submit any info to ATF ever again if nothing in the trust changes.    5 years from now you get another item, cards and a photo, then for another 2 years you're covered again. 

Yes CLEO notification is required for everything regardless of the entity or item. 
These are my interpretations when I went through it.  HTH

 

You have the itch again.....who here would have predicted that?

Edited August 11, 2016 by johnsonlmg41
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[secondofangle]

NEO, some of us tried to tell you this, but your rush to submit prior to 41F conferred absolutely no advantages to you, especially since now you wish to submit stuff post 41F, save for it delayed the fingerprints and photos.  Which now you are going to have to do anyway for post 41F submissions.  Which lasts for 2 years.

IIRC, you printed everything on card stock or some high quality paper and send CDs and DVDs and all sorts of unnecessary supporting documentation to ATF (which I wager, if it does anything, it will slow processing of your applications).  Given this proclivity you have of going overboard, I cannot possibly understand why you thought that some fingerprints and photos were going to slow you down and thus justified your pre-41F rush.

Slow down for a minute and try to understand the process.

[Marshall U]

Well...instead of all the admonition and brow beating...people could just...you know...offer HELPFUL SOLUTIONS!?!?!? For instance...

Hi Neo,

Thanks for engaging us all and posing such very good questions. Your input is insightful, constructive and thought provoking. In answer to your question, you could simply FORM ANOTHER REVOCABLE TRUST. Your original trust with all your class 3 items (purchased pre-41F) will not be subject to all of the new nonsense (your goal). There is no stipulation that you cannot have as many living trusts as you desire. I have several friends that have created trusts for every single class 3 item they own. This was done because even if the C^*KS>~KERS at the federal level ever ban transferability, you can just "sell" the right to be named a co or sole trustee of the trust that owns the individual class 3 item. Ownership would not technically change; only the custodial and fiduciary duties of maintaining the living trust. 

High Five Neo...middle finger to all of the cynics...now back to my friggin Mai Tai. 

AS for the MODERATORS...

***C^*KS>~KERS=CORKSLIKERS***

 

Edited August 23, 2016 by Marshall U

[boss429]

Marshall U, Nice tip about forming multiple trusts.

[Neo]

Quote

On 8/15/2016 at 0:16 PM, secondofangle said:

your grasp of the point of a trust and of 41f and their advantages and disadvantages is fragile at best  Youre spouting off "IM GOING TO GET A TRUST AND CRAM ON 50 NFA items before July 13th so theyre grandfathered!") like you have discovered some sort of Rosetta stone when in reality this big rush does you no good because your current trust is empty. Unless there is some problem with NEOs fingerprints that we dont know about. All this to save you one set of fingerprints and a passport photo.  

I cease and desist attempting to help you. There is no point youre immune to all information that doesnt suit you for whatever reason 

You will just troll the internet (as in trolling motor, not urban dictionary trolling - sheesh) and become a de novo expert in all matters NFA - regardless of having ZERO practical experience in the matter other that opening a checkbook.

 

Photos of the machine guns were printed on photo paper at Walgreen's.  CD that I included has the original resolution digital files, though I highly doubt that the NFA branch can access the CD since their puters are likely still using Win 3.1 w/ 5.25" floppy drives.  Though I do welcome any delay my efforts bring, since there are still forms that haven't cleared to my local SOT yet.  Hoping the ATF doesn't start processing my forms that were submitted on July 12th until half a year from now, by then everything would have cleared to my local SOT you see.

@Marshal: That's an interesting solution, creating new trusts for each NFA purchase under 41F for the intent of selling a trustee slot or sole trustee rights.  I like that.  Would be a tad complicated as I'd have to remember which items go with which trust, but its an option to consider.  Plenty of time to decide since any purchases would require months before a form cleared to my SOT, and I'll no longer require my SOT to file prematurely since there's not that impending 41F deadline to meet anymore.  Ironically, transferring to a newly created post-41F gun trust was the ONLY poll option that no one voted for on my thread over at HKpro (though this is a private thread hidden in the premium content, so the sample pool is heavily restricted).  As seen here:


I visited my local SOT today since much has cleared by now.  The primo toy, the controversial transferable M4 Commando Enhanced, cleared transfer by form 3, was NOT reclassified as a post-sample, and arrived this week!

Edited August 26, 2016 by Neo