I asked my lawyer, I have a trust. There's a comment section in federal registry, I highly recommend you go register your opinion. I doubt many anti's will as they don't know anything about this, just us for the most part.
You still have to transfer the device on a 4473 for a rifle suppressor or rifle, so you still get a background check on whichever trustee picks it up as is. And any trustee that violates NFA basically looses the protection of the trust, same for beneficiaries. At least that's how I understand it.
What they WANT, is that you include photos and fingerprints for trustees and I think beneficiaries. That'd be a total of three for me, two trustees and one beneficiary. The sign-off *I think* isn't the same as begging for permission as it stands now. It is supposed to be a generic background check that they send off to ATF saying you are or you are not a criminal. I don't think they have a choice in NOT doing it in this instance. But they'd have to do it for, say, three people in my instance.
If you do it for yourself only, it'll be infinitely easier.
You also still get the protections of the trust, which I always say is actually worth it even if you couldn't buy NFA items the way you can. And if they add this rule and it doesn't increase the wait time or make it more difficult to obtain while preventing them from falling into the wrong hands and being used in crimes (they've had a stellar track record so far) then I may be okay for that, but I also understand "an inch a mile" and how they've been working this thing, so in essence I'm against it.
But I'd still get the trust. If nothing else but for your family so as to provide more protection for them. I don't know how the law will work or if there will be a loophole, but it may be possible for you to purchase as the only trustee, then add beneficiaries later. Then revoke them for the next purchase and so on.
If you only have to submit the fingerprints and photos and background check the one time for trustees and beneficiaries, then that'd obviously be a lot better. But I haven't gotten 100% clarification as they haven't adopted anything yet. Changes can still be made I suppose.
You need to contact a lawyer, whoever sets up your trust. He'll be able to tell you the changes and maybe what to do in the interim if you are planning on one. Know you can get an entire estate trust, not just NFA, and have that as just part of it as a perk. Actually not a bad deal, really.