Even among veteran stamp collectors most have probably never seen a Form 3, but they need one every time they buy a new product from a dealer. The Form 3 is what licensed dealers use to tell the ATF that ownership of a registered NFA item is transferring from one licensed party to another, and in theory it should simply be a rubber stamp process. Both parties are already licensed, all that needs to happen is that the ATF updates its books and sends the green light to the dealer in question. This simple process should be instantaneous with the technology available today, but instead it still takes nearly a month for paper copies to work their way through the system and back. The ATF was planning on digitizing the process to make things easier but apparently that has once again been pushed back. And also delayed the return of the digital eForm 4.
The following email was sent to a select group of licensees who were involved in a small scale test of the system, and based on the report things don’t look good.
We had hoped to be able to present the first iteration of FEAM at the 2016 SHOT Show. Last week we performed an assessment of what was contracted to be developed for FEAM and what the contractor planned to deliver. At the end of the assessment, all parties involved felt that the product outlined in the current contract did not fully provide all the functionality that we expected, or that the industry requested. For these reasons we decided that rather than to continue on the current course, we would take the steps listed below to ensure that FEAM is a worthwhile investment for both the industry and ATF:
- Curtail the current development effort.
- Determine what is needed to sustain the existing eForms system, until the full requirements for FEAM can be determined and developed.
- Make the necessary changes to eForms to stabilize the infrastructure with the ever-increasing user population.
- Determine if we can re-introduce the Form 3 to the current eForms, through load testing and other system validations.
- Perform an assessment of the ATF and industry requirements for FEAM.
- Secure required funding for a new FEAM initiative, based on the revised requirements.
- Restart the FEAM initiative, to include industry participation during the requirements gathering and testing processes.
We look at this as only a minor delay. It is our intention to use this delay to acquire the tools and resources necessary to develop a product that will provide more functionality and a stable workflow process and infrastructure.
Given how unstable and buggy the original ATF eForms website was I’m perfectly happy to cut them some slack and allow them to get the bugs out of the system before they go into full production. Then again, this is something that should have been complete years ago.