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.
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.
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.