Robert K. Merting - Attorney at Law
Trust Your Guns: A firearms, business, and ITAR knowledgeable law practice
Those of you who followed ATF 41F from the time it was ATF 41P know about the two year window. Generally, this is a provision that allows the applicant to certify there has been no change in the entity since a prior approval in lieu of submitting required documents. But what does this really mean? The Read More …
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 …
For those of you who have followed the ATF 41-P proposed rule you know that the ATF is considering requiring additional paperwork and documentation supporting Form 4 and Form 1 applications for entity submittals. Specifically, all “responsible persons” will be required to submit fingerprint cards, pictures, and a chief law enforcement officer (CLEO) sign off. Read More …
Best wishes to all for a Happy New Year! The comment period for ATF-41P has been closed for nearly a month now. About 9,500 comments were submitted, and a quick sampling of the comments show that no one is happy with the rule as proposed. The administration has to listen, but they do not have Read More …
As Congress and the President debate the appropriate level of deficit spending (rather than debate whether to have deficit spending at all!) the clock for ATF-41P continues to tick. As you can imagine, your senators and congressmen have more important dilemmas to address, and it is unlikely that this proposed rule change will get their Read More …