Form 4 Coming to E-File?
The ATF issued a new comment request for proposed modifications to ATF 5320.4, also known as Form 4. This form is used for the application for transfer of an NFA item to an individual or trust.
What does this mean? Basically, before they can change a rule, the BATFE has to put the change out there for comment. This happened with 41F and they’re doing it again…this time, maybe for the better.
In Citation 84 FR 17422, the feds state some estimated numbers…they say about “123,339 respondents will utilize the form” and a “response to a single form will take approximately 227.0598 minutes”. So, reducing time and effort is their goal.
They Continue…”An estimate of the total public burden (in hours) associated with the collection: The estimated annual public burden associated with this collection is 466,775 hours, which is equal to 123,339 (# of respondents) * 1 (# of responses per respondents) * 3.78433 hours (227.0598 minutes).”
So, basically, they are not coming directly out and saying there will be e-filing of Form 4 in the near future…what they are saying is they are looking at adding some terminology, changing some questions, and changes to the instructions…maybe, “through the appropriate automated, electronic, mechanical, or other technological collection techniques, e.g. permitting electronic submission of responses” means they’re actually considering it.
Here’s the deal, if you enjoy NFA and hate the year long wait to get something you bought and paid for…you need to comment. Tell the Feds you want this to go through. Don’t use the “muh rights” argument. Do use logical reasons like responsible persons, reducing postage, burden on the USPS, previous approvals, time used could effectively be used elsewhere, money saved by reducing time and effort…all kinds of different positive reasons can be used to effectuate positive change.
If you want to read the Summary here is the link in the Fed Reg: https://www.federalregister.gov/documents/2019/04/25/2019-08314/agency-information-collection-activities-proposed-ecollection-ecomments-requested-revision-of-a#further-info
Here is the actual PDF: https://www.govinfo.gov/content/pkg/FR-2019-04-25/pdf/2019-08314.pdf
As an aside, they are also looking into changing formatting, additional questions, and updates to the instructions of 5320.1 on the ATF Form 1, 5320.5, ATF Form 5, and the responsible person form. Here is a link to all the proposed changes… https://www.federalregister.gov/documents/2019/04/25