NFA Form 1 for suppressor - request for additional information

[NuclearFred]

All, I am new to forum and have one tax stamp for a suppressor filed last year. I recently filed a new F1 for another suppressor I wish to make and got the following request for additional information before they will continue - Anyone else seen this activity and any ideas how best to reply? They are requesting via email and snail mail

NFA Division requests that you provide certain additional information so that it may determine whether your eForm 1 application to make a silencer may lawfully be approved. Specifically, please submit to NFA Division the following:

• Pictures of the parts that you will use to make the silencer (the pictures should be clear and allow the identification of the parts photographed),
• A description of the processes you will use to assemble or fabricate the silencer,
• The product, model, or kit name, if any, of each device and/or part that you will use to make the silencer, and
• The source from which the parts were obtained, i.e., the name of the store, website, etc.

 

[Chucktshoes]

The ATF has recently unilaterally determined that “solvent traps”, the associated parts and kits are already suppressors. They recently issued a blanket denial of Form 1s and then have sent out these letters requesting more information about how to applicants intend to build out their form 1s. Considering that the ATF is asking for information that may be determined to be self incriminating at a later date, I would strongly suggest seeking legal advice from an experienced attorney in the realm of NFA matters before deciding on and proceeding with any course of action whatsoever. 
 

https://www.gunsamerica.com/digest/asa-and-prince-law-take-notice-of-form-1-suppressor-denials/

[DHF]

The American Suppressor Association has been sending out notifications and call-to-actions on this as well for the reason stated above by Chucktshoes.

https://americansuppressorassociation.com/atf-form-1-update-take-action-now/?mc_cid=741b756079&mc_eid=0afb189d88

[NuclearFred]

Thanks for the advice. I have until March 27 to respond, so best to find an attorney quickly. I was intending on using various providers parts (but all are marketed as "solvent traps") which seems to be a "hot button" for the ATF these days. I don't own a CNC so, not sure how I would manufacture without basic baffles and a titanium tube.

[Chucktshoes]

15 minutes ago, NuclearFred said:

Thanks for the advice. I have until March 27 to respond, so best to find an attorney quickly. I was intending on using various providers parts (but all are marketed as "solvent traps") which seems to be a "hot button" for the ATF these days. I don't own a CNC so, not sure how I would manufacture without basic baffles and a titanium tube.

If you haven’t purchased any parts yet, I would think that puts you in a much better position with regards to avoiding anything too intrusive by those assholes. 
 

Don’t answer that, it wasn’t intended as a question. 

Edited March 14, 2022 by Chucktshoes

[Chucktshoes]

 

[Protongunner]

It appears that the form one route for building your own suppressor has been all but totally eviscerated. From what I gather most folks who are in the pending state with a form1 submission are going to play it safe and let their submission be disapproved rather than send any photographs of any materials they may have on hand. It's definitely a confusing time and bad luck for anyone who had recently tried to start their first form one can. You may have noticed that the vendors who were selling trap parts have mostly shut down because of this response. On the bright side I have seen some reports of form 4 suppressors filed with the form4 electronic system coming back in under 90 days already.

Edited March 15, 2022 by Protongunner

[LawVol]

unless you just really want to be a test case on how this all shakes out, I'd ditch the plan to make a form 1 suppressor, get your $200 back, and put it toward a form 4 can.

[Protongunner]

10 hours ago, LawVol said:

unless you just really want to be a test case on how this all shakes out.....