Who’s Your Responsible Person?

ATF 41F, the final implementation of ATF 41P, has raised many issues. None of them are more confusing or more important than who is a ‘Responsible Person’. The exact meaning of this term, or more importantly who is included, decides just how much paperwork a trust must submit for a transfer. The Definition For starters, Read More …

What happens with a CLEO Notification?

The new requirements under ATF-41F changes the old CLEO certification to a CLEO notification, and extends this to trusts and other entities. So what will happen with that notification? In theory, the CLEO will be under no requirement to investigate the trust or “responsible person.” But they can alert the ATF to a legal prohibition against Read More …