ATF Form 4
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Since they were first regulated in 1934, delays associated with Form 4 processing have been a reality that the suppressor community has had to live with. For years, the American Suppressor Association (ASA) has actively advocated for changes to the process to improve efficiencies and decrease delays. According to ATF, the months-long wait times we have unwillingly become accustomed to may be a thing of the past.

At the end of 2023, the ASA coordinated an Industry Roundtable with ATF to discuss problems and offer solutions to many of the underlying issues slowing down the eForms system. On March 15, 2024, the National Firearms Act Division hosted a webinar to discuss the processing improvements they have recently implemented.

These improvements, many of which are a direct result of ASA’s Industry Roundtable with ATF, have helped dramatically speed up Form 4 transfers, bringing many approvals down to mere hours! While there is still tremendous variability in transfer times, ATF openly stated that the new and improved processing times are the “new normal” and are expected to continue.

During the webinar, we learned a lot about the latest processes that ATF is employing to all but eliminate wait times. We’ve summarized the details into an FAQ, so let’s dive into what we were told:

How is NFA Division currently processing forms?

In order to process an NFA application, ATF must first receive a response from the FBI National Instant Criminal Background Check System (NICS). The NFA Division currently submits NICS checks to the FBI in large batches. Rather than approving transfers sequentially based on date received, NFA examiners are now focusing on rapidly processing applications as soon as the NICS response has been received.

According to ATF, the “NFA Division is processing eForm Individual applications in real-time” and will quickly do the same for Form 4s utilizing an NFA trust. Translated, this means that as soon as an approved NICS check is received by ATF, the NFA application is processed for final approval.

The NFA Division has established several “swimlanes” where forms are funneled to examiners for processing to streamline the process further. These swim lanes are:

  • Individual Applications
  • Bundled Individual Applications
  • NFA Trust Applications
  • Bundled NFA Trust Applications

What is “Bundling”?

This is the term the NFA Division uses to identify an individual or trust with multiple pending applications in queue. These applications are for items purchased at the same time or over a period of time. When bundled, the NFA Division identifies these applications and packages them together so that a single NICS check can be submitted and all pending applications can be approved simultaneously. This reduces the overall number of background checks sent to FBI-NICS and allows NFA examiners to efficiently process multiple applications simultaneously.

What led to the rapid decrease in Form 4 processing times?

Changes in basic processing methods are responsible for the rapid decrease in Form 4 processing times. While paper forms will always be accepted, the NFA transfer process has been optimized to more efficiently process electronic applications. With roughly 96% of all NFA applications submitted electronically, this means more can be processed in a shorter period of time.

Perhaps the most impactful change is ATF’s departure from the “First In, First Out” approach. Rather than waiting for applications to be approved sequentially, NFA now focuses on approving applications as soon as the applicant’s background check has received a NICS “proceed”. Around 70% of background checks receive an instant “proceed” from the FBI’s NICS. The remaining 30% are “delayed” or “denied.”

“Delayed” background checks require further investigation by the FBI-NICS team to ensure the applicant can legally procure a firearm. Delays are often resolved in a matter of moments, but with NFA applications, the delay can sometimes take months. That is because NFA items are not subject to the three-business day statutory window outlined by the Brady Act. In other words, the FBI does not have to process delayed NICS checks for NFA items as quickly as they do for Title I guns (rifles, pistols, shotguns). It is important to note that NFA examiners do not process these background checks; the FBI does.

As of March 12, 2024, NFA has 77,963 open status background checks with NICS – the oldest dating back to May 8, 2023. This is a leading cause for the wide range of approval times experienced by consumers.

How can I ensure my application is not delayed?

There is no single silver bullet to 100% ensure that your application is not delayed. However, if you take these steps, the likelihood of a delay is significantly lower:

  • Include your Social Security Numberon your Form 4
    • Including your SSN reduces misidentification during background checks, especially for people with common names.
  • If you are frequently delayed when purchasing firearms, consider applying for a Unique Personal Identification Number (UPIN).
    • UPINs are assigned by the FBI to help applicants who experience frequent delays or wrongful denials quickly prove that they are not a prohibited person. 
    • If you have a Unique Personal Identification Number (UPIN), include it.

What improvements are being made to expedite the processing of NFA trust applications?

The NFA Division is working to implement several improvements to the processing of trust applications that will all but eliminate the gap between individual and trust applicants. This will be especially true for applicants using “standardized trusts” sold by reputable companies, which have already been thoroughly vetted by ATF. Because they have been vetted, they require less manual review by examiners.

The NFA Division will also do away with the paper Responsible Person Questionnaire (RPQ) that must be completed by each Responsible Person (RP), scanned, and attached to trust applications. Instead, they will incorporate an electronic RPQ(s) as part of the eForms system. This will reduce common errors encountered with trust applications and reduce the workload on both the applicant and NFA.

For more details on ensuring an expedited trust application and other details on eForms processing, visit the ASA.

This article courtesy of the ASA.

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32 COMMENTS

  1. If the fed really wants a registry all they have to do is incentivize or just lower the barrier to NFA item ownership. Folks will climbing over each other to register.

    • They already have a pretty good start at a registry… 5 gunshops that I had purchases at through the years closed up shop and turned over their books, and a local farm/fleet store chain recently had to turn over their books from all of their stores due to being investigated for straw purchases. With the ATF yanking FFLs for minor violations, that will mean additional surrendered books…. I’m glad the majority of my acquisitions were private party deals or trades.

      • Anyone that has filled out an electronic 4473 (as at a big box gun retailer) = same direct feed into the lair of the JBTs

    • Shire-man,

      I am 99.9% certain that search engines and hosting services (read: computer servers providing the websites that we all visit) voluntarily hand over our Internet activity data to fedzilla. I am also 99.9% certain that our “smart” phones are frequently listening to us and voluntarily hand over key word data to fedzilla.

      So, unless you never use a computer or “smart” phone in association with your firearm advocacy and possession, fedzilla has an amazingly accurate profile of you with respect to firearms.

      Therefore, you might as well acquire any NFA item that you want.

      Furthermore, there is significant value in fedzilla knowing that We the People are armed to the hilt: it provides a huge deterrent to overly ambitious would-be tyrants.

    • “If the fed really wants a registry all they have to do is incentivize or just lower the barrier to NFA item ownership.”

      You’re telling me reported current NFA wait times as low as 1 day isn’t low enough of a barrier for you? Seriously?

      I’ve been saying for *years* here in TTAG there was zero reason with the federal government as interconnected as they are with digital data that NFA wait times needed up to a year to clear, and now that looks like it finally happened…

  2. With all the 4573s I’ve filled out over the last half century or so it’s pretty clear ATF has me on the “list.”

    I guess I am going to get a couple of silencers, just to try to save some of what is left of my hearing. Tinnitus suc.Ks and I would rather it not get any worse.

    • Russ, you really, really, *REALLY* want a good .30 cal can for subsonic .300 BLK, and maybe a .22 can for backyard plinking…

      • Yep, I am doing my research on a .22 silencer that will handle the pressure of a 5.7 and a light weight .308 can for my Blackout, Grendel, and 5.56 as that will cover most of my shooting. The 9mm defensive carry pistols will have to wait since I don’t care for the “piston” concept.

        • I’m REAL happy with my Mask HD rimfire and Wolfman Suppressors. I believe the Mask handles all the current rimfires, and the Wolfman handles the 5.56, Grendel & the Blackout, and of course, 9mm. That confirmed by the Manufacturer. When using it in it’s shorter profile. it is still a little ungainly on a full size 9 pistol. But not so much that I’m compelled to purchase another. Yes you will need the piston on the pistol.

    • “Tinnitus suc.Ks and I would rather it not get any worse”

      Right with you there! Not sure which to blame it on. Shooting since a young teen, mostly unprotected of course, working on Road Race cars at the amateur & Professional level, mostly unprotected, or operating pneumatic tools three inches from my ear(s). I finely figured it out sometime in my Thirties. As we get older, we do pay for our youthful Dum_Ass ways

  3. Appears to be a well-designed trap to me…

    The NFA-types have unwittingly been the beta testers being used to fine-tune their final solution for all of us- universal background checks with national registration for every firearm transaction.

    So, now we know…

  4. No one has ever been able to tell me – specifically, what difference is there between the FBI NICS process and the NFA branch processing of Form 4s? Other than the registration of a serial number, what’s the hold up? Since FBI says someone is okay, what does ATF NFA actually do?

    • (The way I understand it.) They hold you up because they can. They get your fingerprints on file. Your local Sheriff’s office is notified of exactly what items you have.

  5. Obviously the 4473 form did not work to catch hunter biden or does paying $200.00 work for a permission slip to own a soot can that can be more trouble than it’s worth. What works much better is leaving law-abiding citizens alone and putting criminals who feed on the law-abiding in prison and keeping them there.

    • Criminals versus Prisons.
      There are not enough prisons to house all the criminals. I say let We the People shoot the thief in the back as he rides away on your bicycle.
      Laws protect criminals.

      • Laws do protect the criminals. So does morality since I would not shoot that criminal riding away with my bicycle. On the other hand the thug breaking into my home in the middle of the night has placed himself in an extremely dangerous position.

        • Yes, however it should be up to the individual on what constitutes the death of a thief. What is in your house that is more important then a bicycle if that bicycle is the only transportation an individual has to commute to and from work, the product magazine, or whatever.
          The bicycle comment was just an example anyway.
          You could look at it this way too, bicycle thievery is just a gateway drug. What’s next?

  6. Permission from your government is needed to exercise a Right.
    Almost sounds like its really not a Right at all.
    Oh duh on me, I keep forgetting any Freedom in America requires money and permission.

  7. I made my own supressors using duck teeth, jelly beans, and possum whiskers. No ducks or possums were harmed in the process..

    • How did you get the duck teeth without harming the duck?
      ,,,,,,,, I can not believe that in China duck tongues can be bought in little pre sealed packages. Like candy, pickled duck tongues. Thank goodness the Chinese never made it to America before the buffalo herds were decimated, they’d have probably used ever part of the American Bison.
      Waste not want not, Grandma used to say.

      • ” A three-finger shot of brandy to start the day ” is what my granny used to say.
        She died on the family farm at 105

    • Yeah, but by definition gun owners are armed; whether they have the stones to defend themselves from tyranny or step into the showers…

  8. “my last was 3 weeks the two previous ones were 3 days each”

    Sure beats a 180 days, which was my last and only experience. Almost shocking that private enterprise spoke to the Gov’ment….and they actually listened.

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