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Eight_is_enough
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You can always do an individual trust, then once it is approved you can add on whomever you want to the trust. That keeps from having to do all the fingerprints, etc. for other members of the trust.
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I respectfully disagree, and if I am right...
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Well, you're wrong.
The most popular trust used in the last four years is Silencer Shops Single Shot Trust:
https://www.silencershop.com/service...hot-trust.html
A trust submitted with one persons name only. When the tax stamp is returned additional persons can be added with no fingerprints, photos or RP questionnaires. No notification to ATF either.
80-90% of my NFA customers apply as a trust and the overwhelming majority use the Single Shot vs traditional gun trust.
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The answer depends on what the effect of Rule 41F was. It went into effect July 15, 2016.
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Huh?
We know about 41F. It merely required the submission of fingerprints, photo and a Responsible Person Questionnaire for each member of a trust AT THE TIME OF APPLICATION.
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If the transfer (of the suppressor) to the trust occurred on or before July 15, 2016, then Responsible Parties ("RP's") can still be added at any time after that, just as before..
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Wrong.
First, it's Responsible Person's, not "Parties".
Second, "on or before"? 41F only applied to Form 1/4 applications not
postmarked prior to July 16, 2016. That's application, not "transferred".
Thirdly, "Responsible Person(s)" is a term used only during the Form 1/4 application process. You don't add RP's later, you add members, trustees or whatever your state law regulating trusts calls them.
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However, if the transfer to the trust occurred after July 15, 2016, then RP's cannot be added, period. That was the whole point of the 2016 rule change. As to transfers made after July 15, 2016, no one can be a RP unless they have applied to ATF and been approved, but there is no way to obtain approval of an RP from ATF unless it has been applied for with the transfer.
The only way to "add" or change RP's for trusts created post-7/15/16 is to do a transfer to a new trust, which requires another $200 stamp and 6(?)-month wait, but in that process you can add anyone you want as a RP so long as they apply and get approved by ATF in the initial application.
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100% horsehockey.
You don't have a clue as to anything about 41F, the NFA application process, trusts or what ATF requires.
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Eight_is_enough
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Ive been told when you have a trust you dont own anything, the trust owns everything??
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A trust is a distinct legal entity, like a corporation.
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No, it isn't. It isn't at all like a corporation.
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And, yes, the trust technically owns the suppressor(s) transferred to it.
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Again, horsehockey.
You confuse ownership with possession.