This is my first post. So if there are any diction errors, etc. Please bear with me. If I get sarcastic....well my apologies in advance.
What follows is my experience with a Form 4 trust and how to speed up the "approval' process. Remember that there is no first in/first out, everything is pretty much chance/at random and, most importantly there is no, zero, nada accountability. The folks I was working with at the NFA are dealing with a broken system with no method to the madness......If you work the system and use your senator (assuming he/she are NRA friendly) you can do better than average.
I checked into the dealers in my area and went with who I thought to be the best. I had an attorney (that the SOT suggested) create the trust for two people. (Putting two people on the trust is a BIG mistake! More on that later).
Once you have completed the paperwork, put money down on the suppressor , written the check(s)*, and the paperwork mailed to the NFA immediately contact your firearms friendly Senator and ask for a privacy form. Your senators office will NOT be able to contact any one at the DOJ (i.e. FBI) or NFA on your behalf without this form in hand. Of note, my Senator would not accept any electronic forms of the Privacy Release. I had to complete everything via snail mail. If the office does not know what you are asking for then reference the Privacy Release Act of 1974 (Public Law 93-579). The office may send this via email (which mine did) but had to be completed and snail mailed back. Also, there is no place 'on line' to get this form. Each senator has a personalized format that they use. My original contact was via e-mail and with my interface with the senators office I never once talked to the guy. EVERYTHING was via email, Of note, once you have a persons/staffers name in your senators office always work with this individual. Once the form is filled out you will also need a professional and polite cover letter with an introduction to include name, address, phone number and personal e-mail etc....and the serial number, type, description, caliber and Trust name (or individual).
* - on the matter of the check(s). I used certified checks from my bank. This way there would be absolutely "zero" chances of an issue with clearing. And, I told my bank I wanted to be notified via email when the check cleared.
I would suggest that getting the privacy release form be requested the second the paperwork is sent to the NFA, assuming you have the serial number,. Don't wait until they (the NFA) sends the application to the FBI.
So now you have the paperwork sent to the NFA and are in the process of getting the privacy release form from your senator....and you wait.
Your bank calls and let's you know when the check was cashed....now you can go to work....the clock starts ticking.....give it 5 to 10 working days and call the NFA in West Virginia (1-304-616-4500) and ask about the status of your application. Again, you need the serial number, trust (or individual) name, etc. Get the first and last name of the NFA service person you are speaking to...be polite...remember all day, every day they are getting calls with impatient and/or upset individuals. A little tact goes a LONG ways...And, this person will be the only person you ever talk to....if you call in and get "sam'....ask to be transferred to the original service person. And yes you may get put on hold...deal with it. If you call at 9ish central time I never really had to wait that long. After a while I got to know my service person very well....
You supply the needed information and ask about the status...and you will get the reply..."Your application is not in the system." In which case you ask, "Why not the check was cashed two weeks ago?"....and see what they say. If you are not happy now you go to your senators office (which has your DOJ clearance form in hand). IIn my case via email with the senators office and tell them who you talked to, what time you talked to this person and when the check was cashed. Follow up with an e-mail to this specific person if possible. And you wait...about a week and call back to the NFA (talking to the same person...asked to be transferred if need be) and ask the same question....and keep up this merry-go-round until you hear the magic words, "Your application is in the system.". Now here is where you need the NFA "Secret De-Coder Ring". "Your application is in the system" really means you are not asking the right question and this is all the information I will supply. What you need to ask next is "Has my application been forwarded to the FBI? If the reply is "no', then ask when....So if the NFA person says two weeks..call back in two weeks and if still not forwarded to the FBI then right back to your senators office...and let them make the call....Remember that this is 'batch' based system. If you don't push the application thought the system then don't complain about the lead times.
So now a bit about a Trust and multiple persons on the trust. When putting together the trust make sure the cost charged includes adding others at a later date. If you put two (or more) people on the trust this means a DOJ release form for each person...and makes the follow up a nightmare.....If you do have two (or more) on the trust when sent to the FBI these are 'randomized' (for lack of a better term). You would think that the FBI checks would be kept together (as part of the same trust) but....nooooo, that would make too much sense. They (the FBI checks) are all tossed into a pile and each check is separate....I can't prove this but i have 95% faith in my opinion.
Ok, you have confirmation from the NFA as to the date the application was sent to the FBI...so now your application is at the FBI for approval....you can't call them...no follow up is possible....the 'black hole" of the whole process. You contact your congressman via email with the date the application was sent to the FBI......and they follow up....give it 5 to 10 working days.....And call the NFA back (talking to the same person) and find out if they have the FBI approval...if not....back to the senators office. Stay on this merry-go-round until they (the NFA) has the approval from the FBI.
Once the approval is back from the FBI, the NFA assigns the application to a specific individual/inspector. This is the key....ask your service person (the same one every time)..."Has my approval been approved and received by the NFA?"...If yes ask for the specific inspector this application was assigned to... Get this inspectors full (proper name) first and last name spelled correctly and asked to be forwarded to this persons phone. The service person will forward you and there is a 99.9% chance you will go right to voice mail. Leave your name, phone number, personal e-mail, serial number, trust (or individual) name, SOT dealer, etc. and ask "What (if anything) can I do to aid you in the approval?" Is the trust correct? . Call back every day leave the exact same message...you will not get a direct dial number, you have to go thought the service group...but again, ask to be transfer to the same service person...and ask he/she to forward you to your assigned inspectors phone......
Then assuming no response, Call in and working with the same service person....explain the 5 days of voice mails....being polite.....and ask to be forwarded to this inspectors supervisor. Get this persons FULL Name . They will not give you a direct dial phone number ....again 99.9% straight to voice mail...and leave the message:
Good Morning,
This is reference to
Serial Number
Trust (or individual)
Type
SOT Dealer
Phone Number
e-mail (personal)
MY understanding is that my application was assigned to Mr/Mrs/Ms for approval. I have left this person 5 voice mails on this application. I have not received any response/feed back. What do you suggest? Is something wrong/incorrect on the application? Should I keep calling? What are OUR options....
Another piece of advice...when leaving any and all voice mails talk s-l-o-w-l-y allowing these people the time to write down all the information. I got tripped up (cost me a week) as someone transposed a number....
Contact the supervisor twice....And call out the big guns....back to your senator....with a detailed accounting of the status, to include (note: by now you should have the specific person at the senators office email address)
Serial Number
Trust (or individual) name
Type
SOT Dealer
Check Cashed Date
Set to FBI Date
Approved by FBI Date
FBI approval received by NFA
Date Assigned to NFA Inspector
NFA Inspectors Name
Dates (all of them) of Voice Mails to NFA Inspector
NFA Supervisors Name
Dates of all messages to NFA superviors
NFA Service persons name
You have to summarize all the information for the senators staff....in one place at one time. When they make the call if you give them enough ammo (pun intended) and all the information it allows them to 'speak with data'. This in turn leads to results.
In my case I was at 300+ days...and got sick of my SOT telling me to wait. So, i took on this quest on Dec 23, 2018...and even with the government shut down was approved on March 3 (yup a Sunday) and notified via email and a phone call by my inspector that I was approved. (note: once we started trading e-mails he (the inspector) turned out to be a REALLY good guy! ex-air force). I called in on Monday, March 4th and spoke to my service person...the same one that I talked to each and every time..and she told me I was approved and would make sure the stamp/approval was mailed that day....Received at the SOT (who I will never go back to!) on March 11th, 2019.
As it turned out the NFA sent the application to the FBI in March of 2018 and was 'stuck' there as of Dec 23, 2018....and with my senators help I was approved 3 days after the senators office received the DOJ release form.
The $200.00 stamp cashiers check was chased/cleared on January 30, 2018....approval on March 4th,....Stamp in hand March 11th.....405 days.....
Does this take up time....yeah about 10 minutes a day.....and lots of headaches....keep a note book handy and document all calls, emails, etc...It will help when working with your senators office.
On a personal note...I live in Wisconsin and without Senators Ron Johnson's office/staff I would still be tearing my hair out. They were professional, courteous, detail orientated and very, very responsive.
This system is broken, I would use the analogy of General Motors or any fortune 500 company using "Turbo Tax" for their accounting and MIS systems. It is beyond ridiculous. It is unmitigated, unadulterated bullsh#t. Can they do better? Imagine if the IRS was run like this...If we the consumers don't "work the system" it will never, ever get any better.
If you don't mind the wait..sorry for this post...If you want what you paid for , then speak up, be the squeaky wheel, and empower yourself and work with the tools (your senator) at your disposal.
What follows is my experience with a Form 4 trust and how to speed up the "approval' process. Remember that there is no first in/first out, everything is pretty much chance/at random and, most importantly there is no, zero, nada accountability. The folks I was working with at the NFA are dealing with a broken system with no method to the madness......If you work the system and use your senator (assuming he/she are NRA friendly) you can do better than average.
I checked into the dealers in my area and went with who I thought to be the best. I had an attorney (that the SOT suggested) create the trust for two people. (Putting two people on the trust is a BIG mistake! More on that later).
Once you have completed the paperwork, put money down on the suppressor , written the check(s)*, and the paperwork mailed to the NFA immediately contact your firearms friendly Senator and ask for a privacy form. Your senators office will NOT be able to contact any one at the DOJ (i.e. FBI) or NFA on your behalf without this form in hand. Of note, my Senator would not accept any electronic forms of the Privacy Release. I had to complete everything via snail mail. If the office does not know what you are asking for then reference the Privacy Release Act of 1974 (Public Law 93-579). The office may send this via email (which mine did) but had to be completed and snail mailed back. Also, there is no place 'on line' to get this form. Each senator has a personalized format that they use. My original contact was via e-mail and with my interface with the senators office I never once talked to the guy. EVERYTHING was via email, Of note, once you have a persons/staffers name in your senators office always work with this individual. Once the form is filled out you will also need a professional and polite cover letter with an introduction to include name, address, phone number and personal e-mail etc....and the serial number, type, description, caliber and Trust name (or individual).
* - on the matter of the check(s). I used certified checks from my bank. This way there would be absolutely "zero" chances of an issue with clearing. And, I told my bank I wanted to be notified via email when the check cleared.
I would suggest that getting the privacy release form be requested the second the paperwork is sent to the NFA, assuming you have the serial number,. Don't wait until they (the NFA) sends the application to the FBI.
So now you have the paperwork sent to the NFA and are in the process of getting the privacy release form from your senator....and you wait.
Your bank calls and let's you know when the check was cashed....now you can go to work....the clock starts ticking.....give it 5 to 10 working days and call the NFA in West Virginia (1-304-616-4500) and ask about the status of your application. Again, you need the serial number, trust (or individual) name, etc. Get the first and last name of the NFA service person you are speaking to...be polite...remember all day, every day they are getting calls with impatient and/or upset individuals. A little tact goes a LONG ways...And, this person will be the only person you ever talk to....if you call in and get "sam'....ask to be transferred to the original service person. And yes you may get put on hold...deal with it. If you call at 9ish central time I never really had to wait that long. After a while I got to know my service person very well....
You supply the needed information and ask about the status...and you will get the reply..."Your application is not in the system." In which case you ask, "Why not the check was cashed two weeks ago?"....and see what they say. If you are not happy now you go to your senators office (which has your DOJ clearance form in hand). IIn my case via email with the senators office and tell them who you talked to, what time you talked to this person and when the check was cashed. Follow up with an e-mail to this specific person if possible. And you wait...about a week and call back to the NFA (talking to the same person...asked to be transferred if need be) and ask the same question....and keep up this merry-go-round until you hear the magic words, "Your application is in the system.". Now here is where you need the NFA "Secret De-Coder Ring". "Your application is in the system" really means you are not asking the right question and this is all the information I will supply. What you need to ask next is "Has my application been forwarded to the FBI? If the reply is "no', then ask when....So if the NFA person says two weeks..call back in two weeks and if still not forwarded to the FBI then right back to your senators office...and let them make the call....Remember that this is 'batch' based system. If you don't push the application thought the system then don't complain about the lead times.
So now a bit about a Trust and multiple persons on the trust. When putting together the trust make sure the cost charged includes adding others at a later date. If you put two (or more) people on the trust this means a DOJ release form for each person...and makes the follow up a nightmare.....If you do have two (or more) on the trust when sent to the FBI these are 'randomized' (for lack of a better term). You would think that the FBI checks would be kept together (as part of the same trust) but....nooooo, that would make too much sense. They (the FBI checks) are all tossed into a pile and each check is separate....I can't prove this but i have 95% faith in my opinion.
Ok, you have confirmation from the NFA as to the date the application was sent to the FBI...so now your application is at the FBI for approval....you can't call them...no follow up is possible....the 'black hole" of the whole process. You contact your congressman via email with the date the application was sent to the FBI......and they follow up....give it 5 to 10 working days.....And call the NFA back (talking to the same person) and find out if they have the FBI approval...if not....back to the senators office. Stay on this merry-go-round until they (the NFA) has the approval from the FBI.
Once the approval is back from the FBI, the NFA assigns the application to a specific individual/inspector. This is the key....ask your service person (the same one every time)..."Has my approval been approved and received by the NFA?"...If yes ask for the specific inspector this application was assigned to... Get this inspectors full (proper name) first and last name spelled correctly and asked to be forwarded to this persons phone. The service person will forward you and there is a 99.9% chance you will go right to voice mail. Leave your name, phone number, personal e-mail, serial number, trust (or individual) name, SOT dealer, etc. and ask "What (if anything) can I do to aid you in the approval?" Is the trust correct? . Call back every day leave the exact same message...you will not get a direct dial number, you have to go thought the service group...but again, ask to be transfer to the same service person...and ask he/she to forward you to your assigned inspectors phone......
Then assuming no response, Call in and working with the same service person....explain the 5 days of voice mails....being polite.....and ask to be forwarded to this inspectors supervisor. Get this persons FULL Name . They will not give you a direct dial phone number ....again 99.9% straight to voice mail...and leave the message:
Good Morning,
This is reference to
Serial Number
Trust (or individual)
Type
SOT Dealer
Phone Number
e-mail (personal)
MY understanding is that my application was assigned to Mr/Mrs/Ms for approval. I have left this person 5 voice mails on this application. I have not received any response/feed back. What do you suggest? Is something wrong/incorrect on the application? Should I keep calling? What are OUR options....
Another piece of advice...when leaving any and all voice mails talk s-l-o-w-l-y allowing these people the time to write down all the information. I got tripped up (cost me a week) as someone transposed a number....
Contact the supervisor twice....And call out the big guns....back to your senator....with a detailed accounting of the status, to include (note: by now you should have the specific person at the senators office email address)
Serial Number
Trust (or individual) name
Type
SOT Dealer
Check Cashed Date
Set to FBI Date
Approved by FBI Date
FBI approval received by NFA
Date Assigned to NFA Inspector
NFA Inspectors Name
Dates (all of them) of Voice Mails to NFA Inspector
NFA Supervisors Name
Dates of all messages to NFA superviors
NFA Service persons name
You have to summarize all the information for the senators staff....in one place at one time. When they make the call if you give them enough ammo (pun intended) and all the information it allows them to 'speak with data'. This in turn leads to results.
In my case I was at 300+ days...and got sick of my SOT telling me to wait. So, i took on this quest on Dec 23, 2018...and even with the government shut down was approved on March 3 (yup a Sunday) and notified via email and a phone call by my inspector that I was approved. (note: once we started trading e-mails he (the inspector) turned out to be a REALLY good guy! ex-air force). I called in on Monday, March 4th and spoke to my service person...the same one that I talked to each and every time..and she told me I was approved and would make sure the stamp/approval was mailed that day....Received at the SOT (who I will never go back to!) on March 11th, 2019.
As it turned out the NFA sent the application to the FBI in March of 2018 and was 'stuck' there as of Dec 23, 2018....and with my senators help I was approved 3 days after the senators office received the DOJ release form.
The $200.00 stamp cashiers check was chased/cleared on January 30, 2018....approval on March 4th,....Stamp in hand March 11th.....405 days.....
Does this take up time....yeah about 10 minutes a day.....and lots of headaches....keep a note book handy and document all calls, emails, etc...It will help when working with your senators office.
On a personal note...I live in Wisconsin and without Senators Ron Johnson's office/staff I would still be tearing my hair out. They were professional, courteous, detail orientated and very, very responsive.
This system is broken, I would use the analogy of General Motors or any fortune 500 company using "Turbo Tax" for their accounting and MIS systems. It is beyond ridiculous. It is unmitigated, unadulterated bullsh#t. Can they do better? Imagine if the IRS was run like this...If we the consumers don't "work the system" it will never, ever get any better.
If you don't mind the wait..sorry for this post...If you want what you paid for , then speak up, be the squeaky wheel, and empower yourself and work with the tools (your senator) at your disposal.