I'm still digesting the rule, but Silencer News has a good summary of the changes below. For the full text see http://silencernews.com/atf-41p-reading-the-final-rule/#more-753
It's important to note that these changes won't take effect until July. The biggest (and best) news is that the CLEO signature requirement is going to be eliminated for all applicants.
"(1) For trust and other non-individual applicants seeking to make or transfer NFA items, all “responsible persons” are going to have to submit fingerprint cards and photographs and undergo a background check with future applications. Each responsible person must also complete the new ATF Form 5320.23 providing various personal identifying information. There is however an exception for those that have completed a previous application to make or transfer a firearm and had it approved in the previous twenty-four months. They will instead be able to certify that their information has not changed since the previous application’s approval and avoid resubmitting their trust agreement (or other proof of existence), photographs, fingerprints, and Form 5320.23. (See. pp. 246-247).
(2) CLEO certifications are officially a thing of the past once this rule becomes effective. They are replaced by a requirement that the applicant notify “an appropriate state or local official” when applying to make or transfer an NFA item. Appropriate local officials as defined in the rule would include the “local chief of police, county sheriff, head of the State police, or State or local district attorney or prosecutor of the locality in which the applicant, transferee, or responsible person is located.” (See p. 5).
(3) There is more specific guidance for temporary estate matters involving NFA firearms, clarifying that temporary possession of NFA items by a personal representative or similar person during the settling of an estate will not be treated as a transfer. (See pp. 247-248).
(4) Surprisingly, the future addition of new trustees/responsible persons to a trust after a transaction will not trigger any additional paperwork or reporting requirement. (See pp. 123-124)."
It's important to note that these changes won't take effect until July. The biggest (and best) news is that the CLEO signature requirement is going to be eliminated for all applicants.
"(1) For trust and other non-individual applicants seeking to make or transfer NFA items, all “responsible persons” are going to have to submit fingerprint cards and photographs and undergo a background check with future applications. Each responsible person must also complete the new ATF Form 5320.23 providing various personal identifying information. There is however an exception for those that have completed a previous application to make or transfer a firearm and had it approved in the previous twenty-four months. They will instead be able to certify that their information has not changed since the previous application’s approval and avoid resubmitting their trust agreement (or other proof of existence), photographs, fingerprints, and Form 5320.23. (See. pp. 246-247).
(2) CLEO certifications are officially a thing of the past once this rule becomes effective. They are replaced by a requirement that the applicant notify “an appropriate state or local official” when applying to make or transfer an NFA item. Appropriate local officials as defined in the rule would include the “local chief of police, county sheriff, head of the State police, or State or local district attorney or prosecutor of the locality in which the applicant, transferee, or responsible person is located.” (See p. 5).
(3) There is more specific guidance for temporary estate matters involving NFA firearms, clarifying that temporary possession of NFA items by a personal representative or similar person during the settling of an estate will not be treated as a transfer. (See pp. 247-248).
(4) Surprisingly, the future addition of new trustees/responsible persons to a trust after a transaction will not trigger any additional paperwork or reporting requirement. (See pp. 123-124)."
