TFB did a Q&A with ATF. This really stuck out to me:
My understanding was the purpose of the 24 mo. exception was that it was too onerous for a corp to make every 'responsible person' go through that every time if the people don't change. What good is it if only the trust paperwork can be excluded? Is this info inaccurate?TFB:
Do entity documents, fingerprint cards and photographs need to be submitted with each application, even if the applicant has submitted an approved application in the last two years? If not, is there a plan in place to simplify the application process where an applicant can submit the required documentation periodically
ATF NFA BRANCH:
The Form 5320.23, with attached photograph and fingerprint cards, are required in duplicate for each person identified as a responsible person, for each submission, in order to initiate the required background check. The 24-month exemption for providing supporting “documentation” refers only to the documents proving the existence of an entity, such as trusts or corporate paperwork. (On Form 5320.23, see instruction 2 d. (4) and (5) on the Forms 1, 4, and 5. Include date of approved application and serial number.)
