Form 23 DraftFor everybody who is tracking the implementation progress of ATF 41F/41P, the new forms have been published for review.

Take Time to Look Over the Form 4 and Form 23 Drafts

Before linking to the new Form 4 and Form 23 drafts, we want to be clear that these are NOT final versions - and should NOT be used until approved by the ATF & NFA Branch. Here is a link to the new Form 4 (5320.4) draft. Here is a link to the new Form 23 (5320.23) draft.

ATF 41F Form Review Process is Underway

We've been studying these forms closely since the review process started, and have already submitted our first comment on the Form 4 draft.  We're also working on an official comment for the Form 23 draft, and may still submit a second Form 4 comment. As you read through the forms, please take time to bring up any issues you may find since the industry will probably be using these forms for years to come. If you don't want to submit an official comment on your own, feel free to comment on this post and we'll bring any issues to the attention of the ATF during the review process. If you do want to submit your own comment, you can send it directly to nfaombcomments@atf.gov so they can be addressed.  As with the initial ATF 41P comment period, be sure to keep the comments courteous and to the point since we're all facing the current July 13th deadline and need to keep this process moving.

Conclusion

Although ATF 41F is definitely going to add extra requirements and overhead to the NFA registration process, the ATF seems willing to work with industry members to make the transition as smooth as possible. Stay tuned over the next few months and we'll keep you updated as these forms are fine-tuned before the July 13th deadline.