Assignment Sheet For A Form 4?

Aug 14, 2009
Feedback: 29 / 0 / 0
I feel like I've opened a real can of worms on this one, so I thought I'd ask here too. Should I, or shouldn't I include an assignment sheet when sending in a Form 4? My trust is set up without a Schedule A, which is how I prefer it to be, but I'm not sure what to do about the assignment sheet.

When I first made the trust, I was pretty sure the only thing I wanted it for was for e-filing Form 1's. When I did my initial Form 1, I sent in the assignment sheet with the lower receiver on it to prove that my trust was "funded". At the time, the receiver was a Title 1 firearm, and was in my possession, so that seemed pretty straightforward. Now, I'm not sure if I should send in an assignment sheet with a Form 4. I've heard several opinions on this, from lawyers, Class 3 dealers, and regular folks all having a pretty even split on opinions. The options I've been given were...

1) Send in an assignment sheet with the NFA firearm to be purchased already listed on it. (Unsure about this as I won't physically possess the firearm until approved)
2) Send in a blank assignment sheet. (Seems useless to me. My trust does not specifically refer to the assignment sheets in it's main body)
3) Send in an assignment sheet filled out in a manner showing it's "ready to go" when the firearm arrives, ie, filling out the information about the firearm, noting that it is "pending" but leaving dates/signatures blank. (Seems weird to me, looks incomplete at a glance.)
4) Do not send in any assignment sheet as it is not specifically referenced by my trust, and I've already shown the trust to be funded previously. They (should) know that my trust possesses my Form 1'd firearm, and is therefore "funded". I would think that they should also understand that the firearm is being purchased, essentially, by my trust and will therefore be in it's possession when approved.

At this point, I am feeling split 50/50 between 1 and 4. Basically what I'd like to know is what folks here have done, and has it worked or not? I'd specifically like to hear from people using trusts that do not have a formal Schedule A/Schedule 1/List Of Assets referenced in their language.

Thanks in advance for any insight.
While failing to include a completed Assignment Page might not cause your application to be rejected or delayed, there is no harm in doing so. Therefore, I would include a completed and properly executed Assignment Page.

I get your concern about the "chicken or the egg" aspect of the Assignment Page. but it's really not worth concerning yourself over. The "assignment" is really nothing more than a transfer of your beneficial interests in the assigned item, subject of course to ATF approval. They know you can't take possession of the item until you have the stamp in hand, and as long as you don't, you're fine.
Top Bottom