SILENCER SATURDAY #10: Was There An NFA Trust Loophole?

Welcome back suppressor fans. Thanks for reading TFB’s Silencer Saturday, where it’s polite to hush your hosts. Last week we discussed the overly complex NFA transfer and approval process to own suppressors in the United States. After that discussion, two readers sent in questions asking about the use of trusts to own/possess NFA controlled items and if they still make sense after the ATF 41F rule change. Which begs the question: Was there really an NFA trust loophole prior to the implementation of ATF’s new application procedures? Let’s discuss it.


Prior to July 13, 2016, entity applicants (Trusts and LLCs) for NFA Form 4 and Form 1 submissions could forego submitting fingerprints and photographs as part of the background check process. These applicants could also skip the (formerly) required Chief Law Enforment Officer (CLEO) sign off needed by individual transferees. On the surface, It certainly seems like there was a

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