Theohazard, you are incorrect. Please see the first paragraph of page 14 of the linked PDF. ATF is not eliminating the CLEO requirement, to the contrary, they are requiring it for trusts and corporations as well. The only thing that has changed is the language in the CLEO certificate.
If your CLEO won't sign off now, then you are hosed if this regulation goes into effect because it will make that certificate mandatory for all Form 1, Form 4 and Form 5.
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