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SilencerShop is the 800-pound gorilla in the room when it comes to silencer sales. They have been doing an amazing job using technology to keep pace with changing regulations and improve the state of the art when it comes to silencer sales, using things like their SID kiosk and online trust generator to make the process much easier than it once was. Now it looks like they have a new idea on how to improve the process further: one trust per regulated item.

Normally NFA item owners would create a single trust to hold all of their items — every silencer, short barreled rifle, and anything else they want to throw in there. One of the benefits is that trust ownership can be shared; you can add your friends so that they too can borrow your toys should they want to go hog hunting with your new gun that you still haven’t killed anything with.

The issue is that when it comes time to buy a new can, at the moment you’d need to round up all the people you’ve added to your trust and have their fingerprints taken along with your own.

SilencerShop thinks that that’s backwards. Rather than having one trust for all of your silencers, have each silencer in its own trust!

Removing several of the cumbersome steps involved with the typical NFA trust setup (e.g., notary, state filing, etc.), our Single Shot Trust arrangement streamlines the process in many ways. Essentially, Silencer Shop is turning the traditional trust on its head!  Instead of buying a [more expensive] trust and adding silencers to it as you go, the Single Shot Trust is meant to go along with your silencer purchase and be used only for that single item.

No more gathering up all your trustees, taking a trip to the notary, scanning everyones prints, emailing/faxing the trust back to us, and so forth… All you need to do is digitally sign the document and we will send it to the ATF on your behalf. This simple setup allows you to add trustees and responsible parties after you receive approval, to take advantage of the long-term benefits offered by registering as a trust without the hassles of initial set up.

It’s definitely a different way of thinking about the NFA trust process, and the price they’re offering makes it an attractive option. There’s nothing that says you can only have one person per trust. The issue is going to come in the disposition phase — after your death, ensuring that all the stuff owned by the trusts might get messy if there’s a different legal document for every item you own.

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  1. At the disposition phase, is it really worth the hassle of transferring anything other than a machine gun to another individual who is not already on the trust? Would be nice to hear from someone who completed the process.

    • I’m an Attorney who does these trusts, and I also have an NFA Trust. Since silencershop is only selling these in connection to silencers, you wouldn’t be able to connect a machinegun or SBR to it. But lets say you already have a trust- If the Trust has anything good in it, it should have some designation for whom should step in as a future Trustee (without granting them any current trustee powers). That eliminates the requirement of them needing the fingerprints and background checks when adding new items, and then when you pass away the trust property doesn’t need to be transferred through BATFE. The trust is the owner of the property, not the individual.

      Side note- If silencers are removed from the NFA, then these little trusts wouldn’t be necessary. So if you’re ok with waiting a while to see if the act goes through, I wouldn’t put in an application for it.

      Now for my Rant/Concern- I think people could run into a lot of trouble with this new “Single Shot” trust system. I haven’t seen what is actually in the trust, but for something this cheap I wonder what is actually in the document. Trusts aren’t simple little things. You need broad powers to manage, use, and sell the trust property (i.e. the silencer or other nfa items). You have obligations to whom you name as beneficiaries (most states do not allow you to be the sole creator, trustee, and beneficiary). I’m not going to go over all the “Parade of Horribles” but people need to understand that a crappy trust can cause you a world of headache for you if it doesn’t have key provisions (or it will cause trouble for others who will have to deal with the trust property). Depending on what your state requires for Trust execution I think people could possibly run into validity issues. I don’t like this option for long-term use or planning of NFA items.

      I disagree with people having to pay thousands of dollars for a trust, but for a few hundred more you can have a solid NFA trust executed that’ll be effective and, in my opinion, more flexible and less risky for long-term use.

      • My biggest concern with do it yourself legal forms is that people will fill in the blanks wrong because they have no understanding of the legal context.

        It’s not that big of a deal when someone leaves their child to a person as if the child was a piece of property instead of designating that person as the child’s guardian. (A thing that actually happened). In that case, the estate just has to pay an attorney to argue what the actual intent was. Most judges will probably agree. The likely case is that the penny wise pound foolish testator just wasted a few grand.

        When someone screws up a firearms trust, ATF or otherwise, the parade of horribles could include prison rape.

      • I think the Single Shot trusts are in anticipation of the HPA passing.

        If it doesn’t, they could get messy down the road.

  2. I think this is a marketing gimmick to keep Suppressor sales alive while we await the fate of the Hearing Protection Act. The combination of 41F and the wait for the verdict on the HPA has caused Suppressor sales to stagnate. Silencer Shop went from selling tens of thousands of cans a month in the months leading to 41F to maybe a couple of thousand a month the last few months. Got to come up with something to inspire people to buy. This little gimmick looks like a shot in the dark.

    The whole wait for the verdict on the HPA has definitely thrown a wrench into the workings of the Suppressor industry. Things are getting a little desperate. I hope by winter we have some action on the HPA either way. Either it passes and industry sales boom, or things just go back to normal pre-41F sales. Eitehr way is better than this wait and see period.

    If the industry lobby groups were smart, they would all rally around the HPA and push to get it through. Sales are stagnant in the industry overall. The HPA is the boost the industry needs right now. Of all the 2A legislation out there, it also has the best chance of passing.

    • If they were really smart, they would push for an EO revoking 41f in the interim and take a long-view approach on HPA and NFA reform.

      • Agreed. For me the CLEO notification is the deal-breaker. Did it with an SBR build – not doing it again if I can possibly avoid it. If they can’t pass the HPA then need to reverse 41F.

    • Valid point folks are waiting out the HPA to save a couple hundred bucks for a rather pricey item to enhance the user friendly aspect of their firearm. Still it’s kind of an irony these same folks are nearly allowing and industry to fold to save a few bucks! It’s kind of like letting your neighbor lose his house so you can get it cheaper auction. These are the people that drive 45 miles to save 3 cents on a roll of toilet paper at walmart. Only to later be found slapping their own head,unable to understand as to why their own community dried up into a ghost-town. Then that Wal-Mart closes doors and moves on to the next unsuspecting community. You don’t think so, take a little drive out west where there are now new ghost-towns where there were once thriving communities. So while authors help by keep the masses focused on “trivial shit” like can I buy a can easily. The globalist are driving “small town” America into extinction. As a globalist I like having the populus in selected locations of concentrated numbers. I am able to control the poulus easily with one tenth % of the # of sheepeople.

      • Nothing wrong with trying to save a couple hundred bucks, especially when it’s such a large % of the overall cost of a can. Also the time and hassle involved are punitive. F that. I’m not “allowing” an industry to fold, I’m choosing not to jump through extra hoops. 41F had it’s desired effect on me, I’m not messing with it.

      • I suspect sales would have stagnated somewhat even without the HPA. People rushed to buy NFA gear before 41F went into effect, and that used up a lot of the demand. I suspect a majority of the people waiting on the HPA are like me: people who were never going to jump through the NFA hoops anyway, so they’re irrelevant to the current market drop.

        As for “allowing an industry to fold”, two things: 1) if every suppressor maker closed up shop tomorrow, and the HPA passes four months from now, a month later there will be more suppressor makers than there are today. It just isn’t that hard to make a tube with baffles in it. 2) when a company chooses to participate in a market that is artificially manipulated by massive government over-regulation, one of the risks they assume is that those regulations may change in ways that damage their business. It’s just part of the game, and companies that have enjoyed the massive surge in suppressor sales over the last couple years and haven’t put anything aside to cope with this kind of market disruption probably have earned their bankruptcies.

        • “I suspect sales would have stagnated somewhat even without the HPA. People rushed to buy NFA gear before 41F went into effect, and that used up a lot of the demand.”

          ding ding ding
          or do people really not remember the absurd amount of paperwork SilencerShop was shipping out right before 41F?

      • Money isn’t the only issue. The hassle due to the changes and the present year long wait just make the process unworkable for me. I have patience, but not one year patience.

      • Your obviously an industry partner. Look you guys are seriously greedy to charge what you do for what is ascentially a tin can. I’ve got approx. 5 form 1’s, 3 approved and waiting on the 2 to build my own. I’m good. Lower your prices and I’ll buy your pretty packaging.

    • How do you know how much Silencer Shop is selling per day? Are you an employee?

      Or are you just pulling numbers out of thin and and have literally no clue what you’re talking about?

      It has to be one or the other. Which one is it?

  3. I like the sound of how a trust simplifies all the (bs) but, I would only have it for myself. I do not lend my car, underwear, toothbrush, or anything that could be used for a weapon for the most part. I may lend a hammer saw or drill; sometimes. The problem is I know you;don’t get me wrong it’s not that I don’t like you, I really think you’re swell. I have known you all my life and you’re still the same unpredictable emotional creature of passion. You’re not really all that evolved as you give yourself credit for; and you still kill each other for sport or the nike shoe’s on that nigga’s feet. So I believe I hold sufficient rationalization to decline your request to borrow my flint-lock, long-bow, pick-up or boxer shorts. Feel free to add to my list of “shall not lends” at your will.

    • Do you have a wife? If so under current NFA law if a NFA weapon is registered to you, and you are not present you wife can’t access it.

    • It’s not just about lending. It’s also about a legal CYA in case you leave the suppressor or other NFA item in a place where other people might be legally deemed to have access to it. In fact “lending” your can to another person who’s on your trust and not a family member strikes me as rather dumb.

      However, there are other issues such as I said; access. People argue that the BATFE hasn’t prosecuted anyone for this, and as far as I know that’s true, but given the fact that the government has successfully prosecuted people for merely having a gun in the same house as a prohibited person by arguing that the prohibited person might have access to the firearm and therefore is in possession, I don’t want to be the test case.

      In a country where some dumbass can drop a bag of dope in the back seat of my car without my knowledge and the cops can charge me with possession… yeah I’m not playing games with NFA stuff like that.

      • I had a client charged with possession of marijuana. The marijuana was in his car. In his passenger’s pocket. I got the case dismissed. The ADA only dismissed the case because the other guy wrote an affidavit stating that the marijuana was his.

  4. Wasn’t the fingerprint requirement for a trust an Obama era regulation? Trump needs to reverse that ridiculous decision. If John Boch is looking for things to add to his 2A committee to-do list, please do this easy one. It seems like the HPA passage and NFA/GCA repeal have died a slow painful death since Trump doesn’t even seem to be advocating for pro 2A stuff anymore.

    • What planet are you on??? “…slow, painful death..” The bills were introduced in the House and Senate 6 weeks ago! Do you know how long it takes a bill to become a law? Or did you miss that year in school? If you don’t know what you are talking about, sometimes it is best NOT to speak.

      Average Bill to become law is 212 days. That is for Bills that actually become law. Some take much longer, some a few days sooner. But rarely does a bill become law in less than 212 days.

      The HPA has NOT even been voted on in Committee yet. They were just freaking assigned to Committees in the House and Senate a few weeks ago. Dumbass.

      • oh come on jason, cut him some slack. he was just trying to pin more misinformation on obama and make trump out to be a hero. you gotta give him credit for trying. but you are completely right, and like trump, most americans have absolutely no idea how government works. they think throwing money or a politician at a issue will change it. if government shifted directions quickly, we would be be living in the ussr-west right now.

      • So apparently in your dream world, bills get introduced and everyone sits back and waits for passage to just magically happen in 212 days or whatever? Bills get introduced all the time that die in committee or on the floor because they don’t have the 60 votes in the Senate to get past the inevitable filibuster. Successful bills have champions that stir up public opinion and rally fellow congresscritters. Did Obama sit back and just let Obamacare happen? Apparently none of the 2A issues that helped get Trump elected are even on his top 10 list of things he is promoting to get done. So call me a dumbass if it makes you feel good about yourself, but I’ve followed politics plenty long enough to see how things really get done, and if he doesn’t start pushing for the 2A stuff soon, it’ll be midterm election season, and then the re-election, and then… Maybe its time for you to ease up on drinking the Kool-Aid there partner. Dems aren’t gonna let this fly and they are prepared to fight.

        • Actually, according to the Democrats themselves, Obama DID just sit back and wait for Obamacare to pass. Even his own side said he sucked at negotiating.

        • How many sources would you require I cite to completely debunk this nonsensical garbage?

          From Wikipedia on the Affordable Care Act:
          “After his inauguration, Obama announced to a joint session of Congress in February 2009 his intent to work with Congress to construct a plan for healthcare reform.”

          “When Congress returned from recess, in September 2009 President Obama delivered a speech to a joint session of Congress supporting the ongoing Congressional negotiations.[156] He acknowledged the polarization of the debate, and quoted a letter from the late Senator Edward “Ted” Kennedy urging on reform: “what we face is above all a moral issue; that at stake are not just the details of policy, but fundamental principles of social justice and the character of our country.”[157]

          “Obama remained insistent on comprehensive reform. The news that Anthem Blue Cross in California intended to raise premium rates for its patients by as much as 39% gave him new evidence of the need for reform.[174][175] On February 22, he laid out a “Senate-leaning” proposal to consolidate the bills.[176] He held a meeting with both parties’ leaders on February 25. The Democrats decided that the House would pass the Senate’s bill, to avoid another Senate vote.”

          Don’t like Wikipedia? Fine. I could provide any number of other sources that prove Obama was heavily involved in getting the ACA through Congress. When Trump calls a joint session of Congress to press them to get the HPA done, only then will I eat my words.

    • go to Silencer shops link, shows $25 for the single item trust.

      Now the validity of this single trust for so cheap when the industry recently sold us on the value of an expensive “for real” trust, has me a little cautious.

      I want a can right now, the only thing stopping me is spending the money. The SilencerCo “rebate” thing really isn’t enough to motivate me; I don’t have enough hosts for what I’m looking to buy and what I will use it for. When the can itself gets a $200-300 discount, that would force me to loosen up the cash in advance of when it’s super conveniently available.

  5. If HPA passes, it will mean no more suppressor sales in Colorado. The law in this state requires an ATF stamp or you go to jail. Getting our divided legislature to fix the law has zero chance of passing.

    • You poor bastards in Colorado are just too close to “The People’s Republic of California”. You should make any of the (PRC) have a travel Visa and a Passport before they enter the Great state of Colorado for Skiing, and ban them altogether if they overstay their ski trip!!

    • That law doesn’t really bother me. I’ve never once had a cop ask me for paperwork on a can. They’re too giddy at the thought of getting to shoot it. A few have even asked me if it’s “legal” to which I replied “Do I look like the type to flaunt a felony at the local range?” which caused them to forget about the law entirely and concentrate on getting me to let them shoot the host weapon with silencer attached. Even if it was flat out illegal they wouldn’t have cared.

      Besides, most cops (no offense to police out there) would have absolutely no idea what they’re looking at if you handed them a Form 4, which is a tax document anyway, meaning you don’t have to let them read it. Only an ATF or other federal agent can really “demand” to see the document. So flash some paper the way they flash a badge and they’ll likely let you go. Even if you do let them read it, just give them the Form 4 for an old can and they’ll glance at it, see that it looks all official and shit and let you go.

      Or, better yet, just hand them the damn thing and then hand them a mag for whatever the host is. They turn into kids on Christmas morning.

      If the HPA goes through, but out of state, copy and old Form 4 and 99.9% of the time you’ll be fine. Generally though, they won’t even ask you about it unless they want to shoot it. Most of the cops in this state won’t enforce the new gun laws, you really think they’re gonna waste their time enforcing this?

      Unless you live in Boulder or Denver I think it’s pretty much a non-issue. Even then, they have to see the lack of paperwork to prove a crime. “Sorry officer after the HPA I don’t have to carry that and it’s a tax document so no, you can’t see it”.

      • So you’re saying “I got mine, screw everyone else.” There would be no sales within state after HPA and it’s unlikely you could order from out of state. Even a drive to Wyoming wouldn’t be an option because they still require BG check the way it’s written.

        • I’m not saying anything of the type.

          It wouldn’t be regulated like a handgun, it would be like a rifle. I can drive to Wyoming or NM, buy a rifle the that comes with a 30 round mag and come back. Wyoming and the feds don’t try to enforce Colorado law.

          So, you go, you buy, you fill out your 4473 and you ignore the state law in Colorado the same way people, even cops, do with the mag ban and you come back with it. Just like you do now with mags.

        • Or read the bill …


          Section 927 of title 18, United States Code, is amended by adding at the end the following: “Notwithstanding the preceding sentence, a law of a State or a political subdivision of a State that, as a condition of lawfully making, transferring, using, possessing, or transporting a firearm silencer in or affecting interstate or foreign commerce, imposes a tax on any such conduct, or a marking, recordkeeping or registration requirement with respect to the firearm silencer, shall have no force or effect.”

        • Lone Star Legal Eagle:

          Good catch. I don’t have the time do read every bill like this.

          Either way, when it comes to Colorado law, we already have a thriving Irish Democracy and even without that section I feel that would continue to flourish. What Denver doesn’t get is that the rest of us don’t give a fuck what they think.

          • It’s what I do … like for money and stuff. (But being honest, I read or heard about the preemption long before I ever read the bill).

        • Still, you even quoted the section and the direct text rather than making a vague claim that something like this was in there.

          Well done.

  6. I’ve never added anyone to my trust at a later point. Would you then have to send all the FP, etc., to the ATF? Or is it just ‘update and done’? If so, I like that (at least until the HPA, hopefully, passes).

    • Update and done. All you have to do is amend the trust. No BATFE involvement.

      This is why there are provisions in 41F that allow for multiple filings without re-submitting fingerprints/trust doc/etc. UNLESS the trust has changed.

      • There’snactually debate on that. Memos and official statements the BATFE & Large Fires put it suggest that it’s fingerprints and pictures each and every time.

  7. Didn’t happen to mention that SS also sells trusts for you? It’s a creative way to screw people out of their money, I suppose.

  8. I am inspired!
    This one-NFA-item-per-trust idea suggests a novel line of inquiry.
    Suppose I have several NFA items: A; B, C; D; etc. I decide to dispose of C in order to afford to buy G. We know the regime by now: buyer “Buddy” must pay $200 and wait 3 – 6 – 9 months for his paperwork to clear the NFA branch.
    Ahhhhh! but C is in the “OFWG C Trust Dated dd/mm/yy”. I am the trustee and beneficiary. I simply amend the “OFWG C Trust Dated dd/mm/yy” naming “Buddy” the sole successor trustee and sole beneficiary. Collect the agreed upon price, deliver the file of trust documents and the NFA item C to Buddy.
    Observe: No check to the US Treasury; no paperwork to the NFA Branch; no waiting.
    Wonder if there are lawyers among us who might comment as to whether this procedure might work.

    Now, suppose there is considerable concurring opinion that it DOES work. That would be fascinating. Next step; we need to start executing on this practice. After a few years we will observe that Trump’s ATF doesn’t want to try to do anything about the practice. Next, we go to Congress and say that this whole NFA law needs an overhaul.

    Quite apart from which, if any, “firearms” ought to be regulated more stringently than under the GCA, what ought that regulation be? Do we really need a Federal agency (the NFA branch) doing all this paperwork to sell stamps valued at $200 (or $5 for an AOW)? Do we the People really deserve to wait 3 – 6 – 9 months for our “stamps”? Couldn’t this all be done a bit more efficiently than it is now?

    And, what about our wives and children? Do we really need the Sword of Damocles hanging over their heads because – God forbid! – Jr. might go plinking with dad’s SBR? We have to go through a lot of paperwork to put our wives and kids on our trusts only to go through the whole fingerprints rigamarole again when we buy another NFA item.

    • If Pennsylvania has the Merger Doctrine and MarkPA means you’re in Pennsylvania, you and Buddy are felons because there is no trust. But otherwise, yes this should work.

      • My thoughts, exactly. I’m not seeing how they’re able to market this with a single grantor, trustee and beneficiary. My guess is that they’ll start getting kicked back.

        • The thing is, the ATF employee isn’t an expert in the trust laws of all 50 states. Their job isn’t to review the validity of the trust under state law. Their job is to determine if trust is acceptable under federal law.

          I’d be more worried about the ATF saying it’s all good when the trust doesn’t exist under state law for some reason. Then the person with the item is illegally in possession of the item. This would be fine if the feds, and ATF in particular, had a reputation for being fair and reasonable.

      • I’ll start with (since this is a lawyer discussion): IANAL
        Couldn’t you get around Merger Doctrine by requiring that the buyer also designate a beneficiary other than themselves?

        Seems like a bigger potential issue is that there is no way to escrow the trust; at some point in time both the “buyer” and “seller” have to be trustees (before or after money changed hands) at that point either one could have the other kicked out; doing it right, it would be the buyer, but only after money had changed hands, but screwing someone over would have whoever had the money at the time kicking the other one out. The result being that whoever did the kicking, if they had the money, would also be lawful owner of the item. I assume you could get around that issue with some sort of contract, but are there established procedures for “buying” a trust?

        • Or a trustee other than themselves. My point was that Mark specifically said that sole trustee and sole beneficiary.

          Last year, I took the “Everything a Texas Lawyer Needs to Know About Firearms” CLE. One of the presenters said it was probably a good idea to either have a beneficiary who was not a trustee or a trustee who was not a beneficiary. He said he couldn’t find any case in which a trust with the trustees being A, B, and C and beneficiaries being A, B, and C was merged under the merger doctrine, but why risk the malpractice on something that would get everyone felony charges.

  9. “The issue is going to come in the disposition phase — after your death, ensuring that all the stuff owned by the trusts might get messy if there’s a different legal document for every item you own.”

    Not really, you just set it up right were all the trusts have the same successor trustee to administer the passing of the items to your beneficiaries, and you haven’t lost all of your paperwork for your items, then it’s just a matter of keeping your trust paperwork together.

    Also, it shouldn’t be to hard to make sure the trust lasts for, on average, three or four generations. Meaning that your children, grandchildren, and great-grandchildren won’t have to pay a single transfer tax. A corporate person could last in perpetuity, but there are normally annual state filing requirements.

    If you were to come to me to set up your trust, it wouldn’t cost you much to take a trustee on or off or get a new trust. In fact, if you were willing to take the risk of screwing it up or having had the law change on you, it wouldn’t cost you more than printing it up.

    • Screwing it up is the major problem IMHO because it creates a major PITA. My lawyers assured and continue to assure me that my trust is properly written to cover multiple states. The ATF OTOH disagreed and would only recognize it in one and therefore rejected a Form 4 of mine.

      After consulting with my legal eagles I took their advice which was: “The trust is good to go but there’s no way to know why the ATF thinks it isn’t and there’s no point in arguing because their word is the word of God, just do what they say”.

      That little SNAFU took a nine month wait on a can and turned it into a 23 month wait. I wasn’t amused and I’m not going to play that little game again.

      • “My lawyers assured and continue to assure me that my trust is properly written to cover multiple states.”

        What do you mean by that? That the trust is valid in multiple states? I’m just curious as to what your multiple state issue was/is.

        • I’m not a lawyer so I don’t fully understand what happened. That’s why I paid lawyers to deal with the whole thing in the first place.

          Theoretically my trust was altered by amendment after I no longer held residence in New Mexico to accommodate the fact that I am now a resident of Colorado.

          The ATF doesn’t disagree that this is a legitimate thing to do but they disagreed about how it was done on some level. So when I tried to buy a can in Colorado they rejected the Form 4 saying the trust wasn’t “valid” in Colorado. The guys who drew up the trust and altered it for me (legal eagles) contacted the ATF about it (legal vultures) and as far as I can tell much talk of bird law commenced. What I was told was that effectively the ATF folks couldn’t give a justification for why the NFA branch thought the trust wasn’t valid in Colorado but that didn’t change the fact that my application had been rejected. Without a solid reason for that rejection there was no reason to think it wouldn’t happen again and no way to alter things to ensure that it didn’t. Since the lawyers who drew up my trust couldn’t get a straight answer out of the ATF the simple answer was to do an FFL to FFL transfer of the can down to New Mexico and resubmit the application from a New Mexico vendor.

          That was a PITA because not only did it require a transfer and resubmittal totaling nearly 14 months but once the application was approved I had to drive down to Albuquerque to pick the damn thing up.

          • “The guys who drew up the trust and altered it for me (legal eagles) contacted the ATF about it (legal vultures) and as far as I can tell much talk of bird law commenced.”

            Legal eagles, legal vulture, bird law. I’m keeping that one. Probably adding something about how bird law is sacred and must not be violated or you will incur the wrath of (need to find a bird or birdlike god).

            Thanks for helping with my curiosity.

        • I’d go with the Egyptian god Horus. He was the Sky God and God of Hunting and War. He had the head of a falcon.

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