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Anyone ever do bulk transfers?


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I started my NFA journey back in the early 2000's in the great state of Washington. Before the ATF removed the CLEO signoff requirement, getting a Form 4 signed in western WA (the more liberal side of the state) was next to impossible. Folks hadn't quite figured the trust thing out so, like many others, I created a WA State Non-Profit corporation to hold my NFA assets. My wife and I finally got a gun trust done 3 years back and I want to transfer my assets from the corporation so I can collapse it now that I live in TN (I have a buddy back in WA who currently acts as my 'registered agent' and I'm sure he'd love for that to end now that WA is going full California).

Has anyone done a bulk transfer of NFA assets between two entities? I've heard a lot of conflicting reports regarding photos and fingerprint cards.

I've heard:

  • Each Form 4 needs 2 fingerprint cards (per trustee) and photographs
  • I can do 2 fingerprint cards (per trustee) and photos for the whole packet
  • I can do 2 fingerprint cards (per trustee) for the whole packet, but each Form 4 needs photographs

Given that I've got 5 suppressors, 3 SBRs, and an AOW I am hoping to not have to do 18 fingerprint cards for each trustee. Also, for those that might suggest talking to a lawyer, the 3 bullet points above all came from 3 different attorneys 🤷‍♂️

Also, I'm curious if I have to do a Certificate of Compliance for each transfer or can my wife and I each do one for the whole shebang. 

Edited by noid
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I have seen multiple people do batch 4s with only 1 set of paper work per person on the trust and get approvals.  The worst thing that happens is they contact you and ask to send additional paperwork if they are in a bad mood that day. 

 Side note, I have been using the term "public or private" as my mode of transportation on my 5320.20 forms for over 10 years and was always approved.  The last ones I sent in had to be corrected and redone because they wanted the word "conveyance" to be put with it.  I asked why it always worked before and not now all of a sudden, she would only tell me her supervisor said it had to be done.   So, what used to work in the past doesn't always mean it will work now! 

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10 minutes ago, my82cam said:

I have seen multiple people do batch 4s with only 1 set of paper work per person on the trust and get approvals.  The worst thing that happens is they contact you and ask to send additional paperwork if they are in a bad mood that day. 

 Side note, I have been using the term "public or private" as my mode of transportation on my 5320.20 forms for over 10 years and was always approved.  The last ones I sent in had to be corrected and redone because they wanted the word "conveyance" to be put with it.  I asked why it always worked before and not now all of a sudden, she would only tell me her supervisor said it had to be done.   So, what used to work in the past doesn't always mean it will work now! 

Yup. Talk to 4 different ATF agents and you'll get 9 different opinions. 

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5 minutes ago, Omega said:

Why not do electronic fingerprint and photo files.

 

Last time I had checked eForms wasn't able to do a Corp to Trust transfer. That might have changed. I'll check. If so, score one for procrastination!

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4 minutes ago, noid said:

Last time I had checked eForms wasn't able to do a Corp to Trust transfer. That might have changed. I'll check. If so, score one for procrastination!

See if they would accept a CD with those files on it with the paper forms, at least the fingerprint files.

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