From atf.gov:
The final rule affects the NFA regulations by:
- defining the term “responsible person,” as used in reference to a trust, partnership, association, company, or corporation;
- requiring responsible persons of such trusts or legal entities to complete ATF form 5320.23, National Firearms Act Responsible Person Questionnaire and to submit photographs and fingerprints when the trust or legal entity files an application to make an NFA firearm or is listed as the transferee on an application to transfer an NFA firearm;
- requiring that a copy of all applications to make or transfer a firearm, and the specified form for responsible persons (5320.23), be forwarded to the chief law enforcement officer (CLEO) of the locality in which the applicant/transferee or responsible person resides; and
- eliminating the requirement for certification signed by the CLEO.
- In addition, the final rule adds a new section to ATF’s regulations to address the possession and transfer of firearms registered to a decedent.
What this means for purchasing suppressors or SBR's:
The rule change mainly affects NFA transfers to trusts, corporations, or other non-person entities. In fact, for individual filing, the process became easier because law enforcement approval is no longer required. Instead the rule requires that local law enforcement be notified of the filing.
For trusts, which make up the majority of NFA transfers, the process becomes more involved. In addition to filing a new version of the Form 4, every trustee (or responsible person) must fill out a "Responsible Person Questionnaire." The questionnaire includes the "yes/no" checkboxes previously filled out on the Form 4, a 2x2" photograph (passport photo), and duplicate fingerprint cards. The fingerprint cards must be specific cards FD-258 required by the ATF. Fingerprint cards may be ordered from the ATF Distribution Center through the online Distribution Center Order Form, or by calling (703) 870-7525 or (703) 870-7528.
The new forms can be downloaded from the ATF site by following the links below:
- ATF Form 5320.4 - Form 4 - Application for Tax Paid Transfer and Registration of Firearm
- ATF Form 5320.23 - National Firearms Act Responsible Person Questionnaire