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Old August 23, 2013, 01:55 PM   #8
Armorer-at-Law
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Join Date: October 29, 2002
Location: Cincinnati, OH
Posts: 465
Quote:
I think #4 relates to doing away with it all together for all applications. If it eliminates the CLEO certification requirement all together then this is actually a good thing. That is why most people do trusts in the first place.

The new requirements would seem to require that the CLEO be notified but it takes away their ability to deny applicants for NFA items.
Exactly.

Quote:
However, unless they also loosen up the requirements on NFA firearms so that non-prohibited adult family members can have unsupervised access, people will still continue using the trust method since that is the other big ownership problem that a trust or corporation solves.
Correct. Requiring all "responsible persons" covered by a trust/corp/LLC to submit photos and fingerprints is what we would be giving up to completely get rid of the CLEO signoff requirement.

Quote:
Of course, that removes one of the main factors that makes people go the trust route.
If the only reason you used a trust was to avoid the CLEO signoff (often because the CLEO would not sign for anyone), then that problem would go away. If the reason you were using a trust/corp/LLC was so that multiple people would use the NFA item, that would still be available, but each of the persons would need to submit photos and fingerprints.

*Under the proposed rule change, the CLEO would have to be sent a copy of each Form 1 (build) or Form 4 (transfer) submitted, but would have no authority to block it.
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