Ed Ames
Member
This may be impossible to answer, but maybe some of you long-time ATF observers will have some insight.
Form 4s are currently taking 4-6 months to process, meaning if they cash a check on 8/15/2015, the associated form will probably finish processing between 11/15/2015 and 1/15/2016. Could be earlier or later.
The current date for 41p is 12/2015.
How does the implementation of 41P on 12/2015 affect a form 4 submitted on 8/15/2015?
If the form is approved before the final action date, does 41P touch it at all? An example would be if 41P placed new burdens on all existing trusts that own firearms/NFA arms, regardless of when approved.
If 41P comes into effect before the form is approved, will the form be grandfathered in as far as approval rules, or will it be bounced back for responsible person photos etc.?
If the form is grandfathered in, is there any difference between a transfer that was completed before the final action date and after? An example would be if 41P didn't retroactively change rules for existing trusts, but added language to the specific transfer approval that created new rules for the trust.
What are your thoughts?
Form 4s are currently taking 4-6 months to process, meaning if they cash a check on 8/15/2015, the associated form will probably finish processing between 11/15/2015 and 1/15/2016. Could be earlier or later.
The current date for 41p is 12/2015.
How does the implementation of 41P on 12/2015 affect a form 4 submitted on 8/15/2015?
If the form is approved before the final action date, does 41P touch it at all? An example would be if 41P placed new burdens on all existing trusts that own firearms/NFA arms, regardless of when approved.
If 41P comes into effect before the form is approved, will the form be grandfathered in as far as approval rules, or will it be bounced back for responsible person photos etc.?
If the form is grandfathered in, is there any difference between a transfer that was completed before the final action date and after? An example would be if 41P didn't retroactively change rules for existing trusts, but added language to the specific transfer approval that created new rules for the trust.
What are your thoughts?