ATF Requires All Silencer Shop FFL/SOTs to Apply for ‘Variances’ to Use Electronic Signatures

Powered by Silencer Shop Kiosk

Jeremy S. for TTAG

Silencer Shop is the largest distributor of suppressors and silencers (same thing) in the country. Part of that success has been built on their “Powered by Silencer Shop” kiosks they have in gun stores around the country.

These kiosks make processing all of the required ATF-mandated NFA paperwork extremely easy.

Silencer Shop purchase process

Silencer Shop

Part of that process, of course, is signing the required Form 4, among other documents.

See our video here that shows how the kiosks work.

Silencer Shop uses DocuSign as part of the application workflow to capture signatures. But through a brief quirk of the DocuSign system, a small number of dealers who had previously signed other documents (loan applications, whatever) using an established personal DocuSign account, were able to override the parameters set by Silencer Shop to force the use of a live signature when signing the Form 4.

The ATF requires a unique signature every time. Signatures cannot be replicated with a “typed font” signature. So, the few instances where a “fonted” (duplicate) signature was used were a problem.

But instead of issuing error correction letters for those affected purchases, which is the standard operating procedure for errors of this nature, the ATF mistakenly issued disapprovals. Silencer Shop has stepped in and expedited the correction of these applications with the ATF and they’re now in process.

But as a result, the ATF has sent out the letter below to both Powered By FFL/SOTs using Silencer Shop kiosks, and even some non-Powered By Silencer Shop FFL/SOTs.

ATF Silencer Shop letter electronic signature variance

ATF Silencer Shop letter electronic signature variance

ATF Silencer Shop letter electronic signature variance

Translation: the ATF issued Silencer Shop a variance authorizing the use of electronic signatures on their machines. Now, as a result of the DocuSign situation that affected a tiny fraction of the transactions Silencer Shop processes, the ATF is now requiring all FFL/SOTs that use the kiosks (over 650 around the country) to apply for their own individual variances.

TTAG spoke with Silencer Shop yesterday. They told us that they’re working directly with the ATF to resolve this and will be processing the variance letters for all of their Powered By dealers. The good news is that the dealers can continue using the current iteration of the variance through the end of this year, by which time all of the individual FFL/SOT variances should be in place.

Long story short, the inflexible ATF is causing a lot of headaches for (a few) buyers and a lot of dealers around the country because of a minor processing quirk that’s long since been fixed.

Your tax dollars at work.

comments

  1. avatar Texheim says:

    The kiosk was very easy to use.

    1. avatar O2HeN2 says:

      …hence the requirement for the ATF to make the process painful elsewhere…

      O2

    2. avatar LarryinTX says:

      When I dealt with Silencer Shop, it was before the kiosks and while they actually sold the items and helped with the forms (like the old Heathkit company motto, “we will not let you fail!”). Even then, they were outstanding at guiding the process, so that by the time I could actually go pick up my SBR and suppressor (about 3 months), I still did not actually have much of an idea about what had been done. Fill out this, sign that, we’ll get back to you. Really, really, REALLY excellent people. Their business model is changing and expanding, but I have yet to hear a complaint. I really hope whoever dreamed up the concept is getting filthy rich, he deserves it.

  2. avatar million says:

    sounds like SilencerCo is making it right.

    there’s a kiosk near me but alas this is Virginia.. by this time next year all of that registration information will end up on some illiberal leftist’s blacklist.

    1. avatar Geoff says:

      And Virginia will ban suppressors and what to do about the ones in already owned?

    2. avatar LarryinTX says:

      Guys, that is a legitimate complaint, but one which is around 75 years too late. I accepted the fact that my .300 blk SBR and suppressor would be annotated in D.C. somewhere, on a family trust so when my wife and I are gone my sons will still legally have them, but anytime the JBTs can come and get them, since they are REGISTERED!! OTOH, nothing else which I own is registered, nor will be. If I am required by law to turn everything in, they will get the SBR and suppressor. Then, good luck.

  3. avatar Jim Bullock says:

    The A T F seems quite flexible at finding ways to gum up legal purchases, n harrass people who “work with” them.

    Maybe we should have hoped they’d legalize furiously arming the cartels. (Oh, wait. It was all legal. My bad.) The kind of help the A T F gives might have left a few more of those Morman wedding guests alive.

    1. avatar George from Alaska says:

      You are right, of course, but you should put your dog up in a doggie hotel for awhile…

    2. avatar Blue says:

      Hey, Mexico insists that its citizens being totally disarmed, so guess what? That means only the criminals and the government have guns.

      Know how many gun shops are in Mexico? 1 in Mexico City. Government-run.

      They make it difficult to defend one’s self. Don’t blame the U.S. Blame the Mexican government for making their people pawns in the drug wars. Uarmed pawns.

  4. avatar aircooled says:

    Burocrats protecting their jobs. “Look, you can’t eliminate my position! I uncovered a VeRy SeRiOuS procedural violation that affects 0.00001%. You should give me a staff and budget to get to the bottom of this instead!”
    Defund the ATF.

  5. avatar Chris T in KY says:

    I was told the National Socialists put low intelligence type people in as prison camp guards in Germany.
    It seems the AFT has done the same thing.

    1. avatar Chris T in KY says:

      edit
      The ATF has low intelligence guards running the “suppressor jail” system.

  6. avatar Sign here says:

    This whole thing is a crock. There’s no way DocuSign meets the requirement that “the electronic signatures must accurately portray the person’s…signature (i.e., similar to the signature on the person’s identification document). A DocuSign “signature” is just a text block.

    1. avatar LarryinTX says:

      And our children are no longer going to be able to “sign” shitall, they’re not teaching cursive any more. So, why the fuss about a signature?

  7. avatar ronno says:

    If I take the muffler off my car I get a ticket. If I put one on my pistol I go to prison…Typical government bureaucrat nonsense.

    1. avatar sparkyinWI says:

      This ^^^^ It only makes sense to those with no sense, the government.

  8. avatar Ur Children's future Matters says:

    What a scam giving all that personal/bio info for a hearing protection device for a god given human natural right that is just a stupid piece of metal.

    I bet when the hangings start for the NFA Infringements they will repeal it quickly!

  9. avatar Sam Hill says:

    Can you imagine my shock, after working for a year in a government office to learn that government bs did not mean government biblical standards.

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