Purchasers of suppressors, short-barreled rifles, and other NFA firearms commonly enquire how long the process will take. Unfortunately, whenever I answer that question, I’m driving looking in the rearview mirror. I can guess how long a current submittal will take based upon a) the length of time it took to process a Form 4 approved today, and b) a general feel for how busy the ATF has been since the submittal of the latest approved Form 4.
In other words, I start with how long did it take for a current customer to get his Form 4 back, and then I adjust that with a guess based on how busy firearm dealers have been since that date.
Form 4 Status
Currently, we are seeing a one year Form 4 approval process. That process slowed down while the ATF worked through the knot of Form 4s submitted in July of 2016, but it appears now that the vast majority of such forms have been returned to dealers. So we start our guess calculations with an answer of one year.
Now I factor in the general state of business since July 2016. From August 2016, to December of 2016, the industry saw a declining sales rate. Transfers from this time were noticeably down from the similar time frame in 2015. However, there was still brisk business leading up to the 2016 election and on into Christmas shopping. But once we turned the corner to January 2017, business declined again. (This can be attributed to a relaxed and non-alarmed state of firearm owners with the results of the election, the changes in regulations in July of 2016, and the anticipation of further, friendly, changes in the law.) From January 2017 to the present NFA business has been noticeably declined as compared to this time frame in 2015 and 2016.
From the decline in business generally, I can extrapolate that the volume of Form 4s submitted to the ATF is also down. Logically, this means the ATF should work through each month quicker as there are fewer forms to process. Factoring in the decline in sales, I believe a four to six month reduction in wait times is possible. This means we could see Form 4s coming back approved in six to eight months. Of course, we cannot know this until that time has passed.
Form 3 Status
Form 3s are used by dealers to transfer firearms to other dealers. These forms are a good indicator of the ATF’s current work load. As both entities on the form are licensed dealers, the ATF does not require a background check.Unlike Form 4s and 5s which require paper submissions, Form 3s may be submitted electronically. Therefore, with the luxury of computers, the ATF can process these forms much quicker.
This means we get feedback on the state of the ATF much quicker with a Form 3 than with a Form 4. Form 3 wait times had been as long as 60 days recently. However, in the past couple of months that time dropped to a couple of weeks for electronically submitted Form 3s. And most recently, Silencer Shop is reporting same day approvals for Form 3s.
This indicator bodes well for reducing wait times on Form 4s based on current work loads.
NFA Transfers have been markedly down over the past year, and this reduced work load should allow the ATF to catch up on form approvals and slash wait times. This of course is a double edged sword. As wait times come down, more people are likely to buy and thereby increase the ATF’s workload. I have seen a slight uptick in transfers in the last month or so, but volume is still down. If you want a suppressor, now is a good time to get one on order, and you should have it in time to sight in and practice for the 2018 hunting season. If I can help you with the process, please do not hesitate to reach out to me.