CLEO Signature

[ExecDirector]

Several outlets are reporting on our (NFATCA) efforts regarding the sunsetting of the CLEO signature requirements on Form1 & 4. While we are appreciative of the news, there really isn't any *new* news.

ATF has approved it. DOJ has approved it. We are now in the phase where OMB gets to do their regulatory studies, craft the new regulations, propose and draw up the new forms and then submit it to the Federal Register for review. There is absolutely no way to know just how long it will take to get the football across the last yard and the goal line.

I hope that it is soon, though!

[Shermanator]

Everytime I see a post, news article etc... about the removal of CLEO requirement, the source always ends up being the same, YOU :D NFATCA

[ExecDirector]

We're the only ones still banging away at it! We've had a death grip on this tiger's tail for awhile now!

[sillycon]

There have been rumors going around regarding CLEO removal that now all officers of corporations, and all trustees in trusts will now be required to submit fingerprints, photographs, and certification of citizenship forms. Is there any truth behind these rumors?

[ExecDirector]

Just rumors. With that said, it is very likely that a NICS check or equivalent will be required upon the physical transfer of the weapon to the entity (trust, corp, etc). As in, if Joe Blow is the one taking possession of the NFA item on behalf of the corp, a NICS check will be run on Joe Blow. I know a lot of FFL/SOT's have been doing this anyway as a just in case.

[sillycon]

Sounds good.

The concerns I had are that the co-trustee is currently a resident alien, and successor trustee lives in another state (where the trusts NFA contents are legal). As such, having to get signatures from them, fingerprints for them, and any other misc. paperwork together for the both of them to also go through a background check would have made things a LOT more complicated for everyone.

[ExecDirector]

Don't ever under-estimate the ability for a regulation to get overly complicated! While I don't believe that it's possible for ATF to reach back and make this a retro requirement or add this cumbersome burden, it *could* happen if left unchecked. ATF likely has a Deputy Assistant Director of Complication!

[sillycon]

Understood. Like I said, I'd simply seen/heard "buzz" that in order to get CLEO gone the trusts and corps would have to have all "controlling parties" (i.e. officers and trustees/settlors) submit to the equivalent of the individual F4 process.

Thanks again for all you guys do! It's a wonder any of you have hair left!

[Ubetit]

Understood. Like I said, I'd simply seen/heard "buzz" that in order to get CLEO gone the trusts and corps would have to have all "controlling parties" (i.e. officers and trustees/settlors) submit to the equivalent of the individual F4 process.

Thanks again for all you guys do! It's a wonder any of you have hair left!

What a nightmare that would be. It would basically render my trust worthless as my trustees are spread out all over Ohio.

[JohnBrown]

I guess the one thing to keep in mind with the entire CLEO effort is "we don't know" what the details are at this point, aside from the fact that ATF has said, "You will be really pleased with the outcome". On that note I want to cross all of my fingers and toes and hope for the best. All of the rumors about the impact on trusts etc. are just that. Being at the point of the spear on this effort I know. We have been working this for almost five years now and the waiting creates a lot of unfounded rumors. We know this train is on the tracks, we just don't know the contents of the cars. Ever since the day we launched this effort and the original documents were submitted to DOJ we have been kept out of the loop. There are a couple people I trust there that have given me a good level of confidence that this will turn out well. Let's all keep our fingers crossed. Your board of directors has worked extremely hard on this issue.

[Shermanator]

So any update on this?

[ExecDirector]

At last check, which was i September, the project was still with OMB...

[n7qvu]

Any updates?

Jerry

[Shermanator]

Look here, there are two threads about this,, the one here and other one is here: http://www.nfatcaforums.org/showthread.php?6-CLEO-sign-off-Time-line-to-be-effective

[Shermanator]

Just read on the AR15.com Forums that someone was told by a dealer that Trusts are now being kicked back and they have to submit finger prints with them. So did the change go into effect or not? Or is this just Rumor at the moment?

Edit Update:

I did mean to say they are NOW being kicked back.

[ExecDirector]

Not to my knowledge. Though a lot of trusts are getting kicked back, it's because a lot of them are not valid. Cut and paste from the net is dangerous...

[Spinner]

I received two approved Forms 4 for smgs just last week, both in the name of my living trust. These were the third and fourth Forms 4 I've submitted in the name of the trust, and they were processed just like the first two. They weren't kicked back for photos or prints.

[blue70chevelle]

So July is officially over. I see that the ATF is obviously attempting to make progress and thinking of streamlining processes by allowing/accepting online submissions. With the public comment period closed, in regards to the CLEO removal, what is the timeline of events now? IE; when do we find out their decision, if its in our favor how long until enacted, etc.
http://www.reginfo.gov/public/do/eAgendaViewRule?pubId=201210&RIN=1140-AA43

[ExecDirector]

There is no timeline... It's like watching dry paint fade...

[Shermanator]

http://www.reginfo.gov/public/do/eAgendaViewRule?pubId=201304&RIN=1140-AA43

That link is the newest proposed changed and looks like the elmination of the CLEO is removed and this one might read that the CLEO requirement would be required for trust?

[ExecDirector]

Actually CLEO is still in there, they are just using different words to describe it to make it sound less ominous. Notice that the date is 10/00/2013... A date that does not exist. This has not been formalized at this point.

[ExecDirector]

Notice that they have dropped the CLEO reporting issue from the original.

[Jack_Bauer]

Will the CLEO ever go away from the Individual Forms?

[ExecDirector]

We keep working toward that, but the White House has thrown the latest curve ball.