Proposed Examiner Assignments

[ExecDirector]

Following are the proposed Examiner assignments scheduled to roll in November, 2013. It is hoped that even more Examiners will be brought on board as soon as a green light to post official vacancies is given. State Law assignments continue to remain a work-in-progress, as with two of the named Examiner(s) on-boarding next month (November).


Jason Bowers TX . . . . . . . . . . . . . . .
Terry Whittington NC, VA, WV . . . . . . . . . . .
Nicole Dudash IL, IN, KY, OH . . . . . . . . .
Christina Farris MI, MN, MT, ND, SD, WI, WY . . .
Ann Feltner AZ, CA, NV, . . . . . . . . . .
Jason Frushour AR, IA, KS, MO, NE, OK . . . .
Albert Lamberger FL . . . . . . . . . . . . . . .
Eric Leber LA, MS, TN, . . . . . . . . . . .
Daniel Parasky CT, DE, MA,MD,ME,NH,NJ,NY,PA,RI,VT
Dana Pickles CO, NM, UT, . . . . . . . . . .
Shannon Siviero AL, GA, SC, . . . . . . . . . . .
Sandra Snook AK, HI, ID, OR, WA . . . . . .

[RenegadeConservative]

I don't understand why ATF shuffles examiners around. Frushour used to be Montana's examiner, now it looks like it will be Farris.

Examiners should be permanently assigned a specific set of states, learn the specific NFA related laws of those states, and keep abreast of any changes of the laws in those states. Maybe then they could spit out approvals faster.

It's nice to dream, right?

[jason8844]

Why do they list states that are not free (i.e. non-NFA friendly)? I think the best job would be the examiner for CA, NY, HI and IL. All you would do is deny applications if you ever even got one and collect a pay check.

I am actually curious if any of the examiners are collectors of NFA items themselves.

[RenegadeConservative]

Why do they list states that are not free (i.e. non-NFA friendly)? I think the best job would be the examiner for CA, NY, HI and IL. All you would do is deny applications if you ever even got one and collect a pay check.

They still need to process Form 3s, I imagine.


I am actually curious if any of the examiners are collectors of NFA items themselves.

I've often pondered this.

[ExecDirector]

There are now *two* Examiner Supervisors:
Ted Clutter
Kim Ramsburg

As for learning the laws, that area is being addressed by NFA Specialists:
Andrew Ashton
Jon Coleman
Janice Fields
Rob Howard
Sara Jones
Kenneth Mason
Scott Robertson

Amy Stely is the SOT Specialist.

Assignments are based upon volume, aptitude, experience and learning curve. There are roughly a dozen contractors filling the role of Research Assistant to help out the Examiners.

[jason8844]

There are now *two* Examiner Supervisors:
Ted Clutter
Kim Ramsburg

As for learning the laws, that area is being addressed by NFA Specialists:
Andrew Ashton
Jon Coleman
Janice Fields
Rob Howard
Sara Jones
Kenneth Mason
Scott Robertson

Amy Stely is the SOT Specialist.

Assignments are based upon volume, aptitude, experience and learning curve. There are roughly a dozen contractors filling the role of Research Assistant to help out the Examiners.

There seems to be too many chiefs and not enough indians. Is it just me, or is having so many people "learning" the laws (which are fairly static in terms of NFA weapons) seem like a waste of manpower when it could be used for approving applications and helping out the overworked examiners?

[ExecDirector]

Actually, several folks have transitioned from Examiner to Specialist and all of them work collaboratively. Laws and their interpretations are in constant flux. Just figuring out the intricacies of Illinois SBR stuff gives me pause...

[jason8844]

Actually, several folks have transitioned from Examiner to Specialist and all of them work collaboratively. Laws and their interpretations are in constant flux. Just figuring out the intricacies of Illinois SBR stuff gives me pause...

I understand, but "collaboratively" does not mean that when things get really, really, really backlogged, Sara Jones examines Texas applications to help Jason Bowers catch up. Also, I know the Illinois SBR thing only deals with rifles for historical reenactments, so how many can there be? As for the laws being "in flux", As far as I can tell, there are not many NFA related bills in state legislatures at the moment and no NFA related court cases that deal with the interpretation of NFA law. If I am incorrect, I would be interested in reading about them if they could be provided. As it is, NFA law seems to be rather static to me, and unless there is some new SCOTUS case dealing with NFA weapons I am unaware of, I do not see the need to have almost as many "learners" as examiners.

My frustrations are not with the good people at the NFA Branch. They are just doing the job they were hired to do and working within the infrastructure they were put in. In fact, I feel sorry for them. I know they are backlogged with applications that are piled up in boxes and have to deal with impatient NFA collectors, dealers and manufacturers. I am just frustrated with the whole process. I am not calling for repeals, or even removal of certain items that are regulated; I am just expecting the system to run more efficiently. For example, I already own suppressors, so why do they have to run the whole process on me again for the next suppressor? I mean, if I was a bad guy, why would I wait for the next suppressor to go on that crime spree when I already own some? They already have 12 fingerprint cards and 12 passport photos of me on file. They also have well over $1200 of my money and I have nothing to show for it in 10 months of waiting.

I keep hearing that they claim the need more examiners, but yet they keep promoting people to "specialists" who learn the law when the law seems rather unchanged. I am fairly sure that most changes in the interpretation of NFA law would make big news in the gun community and on the NFA related forums.

[ExecDirector]

Jason,
It's not just NFA law that is changing. Remember that transfers to legal entities are now making up a HUGE portion of all transfers that come across the Examiners desks. Knowing whether a given trust, corporation or LLC is actually valid, properly constituted and constructed is a big deal. Each state maintains subtle nuance differences in what they do and do not allow... And states can and do change the rules on an ongoing basis. Multiply that by the number of lawyers, services and ugly cut and pastes that are contributing to the pile...

I've seen trusts that were approved in the past get bounced now because... They are invalid. Did NFA Branch just not check before? Maybe. Are they actually taking the time to check all legal entities now? You bet. You go from a few 100 to 60,000 per year and the process is going to change.

You didn't need a cadre of specialists before.

[mbogo]

From the folks I have spoken to in different state, the growth in the use of trusts is due to the intransigence of some CLEOs who refuse to sign off on Form 4s.

If NFA Branch changed the requirement from requiring sign-off to informing the CLEO (as with 03 FFLs), fewer people would see the need for an NFA trust.

mbogo

[ExecDirector]

This has nothing to do with what the NFA Branch wants. They had bought into getting rid of CLEO a long time ago. The current NPRM is all about what the White House wants...

[jason8844]

From the folks I have spoken to in different state, the growth in the use of trusts is due to the intransigence of some CLEOs who refuse to sign off on Form 4s.

If NFA Branch changed the requirement from requiring sign-off to informing the CLEO (as with 03 FFLs), fewer people would see the need for an NFA trust.

mbogo

I agree. These CLEO think they are sticking it to people by not signing when all they are doing is helping people circumvent a more rigorous background check to get the same legal weapons that are their right to own.

I am blessed to live in Tarrant Count, TX. Sheriff Anderson is a huge supporter of the 2nd Amendment and gun owner's rights. He often gets my Form 1s and 4s back to me in a week. I have never gotten to meet him in person, but I hear he is a great guy and fair and professional law enforcement officer. I will vote for him as long as he continues to run. Because he will sign, I do all my forms as an individual and do not have a need to go through a trust. I am single, do not have children and doubt I ever will, so I do not worry about inheritance issues.

[sillycon]

So when you pass, what happens to your collection?

If it's up to the state, I wouldn't be surprised if it would be surrendered/destroyed.

[ExecDirector]

Assuming that no trust is set up, there is always dreary old probate for the will. You do have a will, right? Your executor can pass the collection to whom you designate via Form 5's. It's not up to the state, unless you allow it to be.

[sillycon]

My point was that it sounded like estate planning hadn't been a concern for Jason, which would cause the state to appoint an executor were he to pass intestate and have no other lawful heirs.

E.g. "if you haven't figured out a disposition for your toys when you die, us other collectors would appreciate it if you did so that they don't run the risk of being destroyed/lost."

[jason8844]

Assuming that no trust is set up, there is always dreary old probate for the will. You do have a will, right? Your executor can pass the collection to whom you designate via Form 5's. It's not up to the state, unless you allow it to be.

No, I do not have a will that deals with my firearms collection. I was thinking in the future I would set it up so my collection (both title i and title ii) of guns would be donated to the NRA or the National Firearms Museum. They could then use them or sell them as they need to raise capital for whatever they need.


My point was that it sounded like estate planning hadn't been a concern for Jason, which would cause the state to appoint an executor were he to pass intestate and have no other lawful heirs.

E.g. "if you haven't figured out a disposition for your toys when you die, us other collectors would appreciate it if you did so that they don't run the risk of being destroyed/lost."

Do not worry, I do not own any irreplaceable transferable MG's. I wish I did though! I only own suppressors and SBRs. So nothing to worry about.

However, I was thinking about having them pile all my NFA toys into my coffin with me! Well, and maybe my prized Colt Python too. I will taken them all with me. LOL

[ExecDirector]

Why does my mind's eye see Slim Pickens riding an ICBM???

[jason8844]

Why does my mind's eye see Slim Pickens riding an ICBM???

I thought that he who dies with the most toys wins. Plus, if I have them in my coffin, the gun grabbers can not get them. LOL

[ExecDirector]

woot!

[sillycon]

Literally "from my cold dead fingers", eh?

[jason8844]

Literally "from my cold dead fingers", eh?

Well, grave robbing is considered a hideous crime on the same level as treason. I guess when it comes to gun grabbers nothing would surprise me though. But it might slow them down having to dig me up to get my prized 9mm AR15 SBR with suppressor. LOL =)

[jason8844]

I was looking at NFA Tracker today and I am starting to notice two new trends...

1. There are new names of examiners showing up, so they are hopefully getting things up to speed with the new hires. However, there seems to be names of examiners that are not even listed on the original post of this thread. One of those names is Joyce Leonard. Did they hire even more than they originally stated? This maybe a good thing.

2. I am noticing that since the start of November the examiner names that are showing up are not with their usual state assignments. For example, our examiner here in TX is Jason Bowers, but I have noticed he is approving Forms from other states and other examiners are sometimes approving Forms from Texas. Does this mean that they have scratched the state assignments and gone to a free-for-all style?

Anyway, I thought I would just share my observations.

[ExecDirector]

Will check into this... assuming my inquiries are returned...

[jason8844]

Will check into this... assuming my inquiries are returned...

Thank you. I am just curious. I hope it is good news and that the NFA Branch is finally getting the funding and personnel they desperately need.

[ExecDirector]

It's not nearly enough and it does not cover the folks that have moved on *after* the new folks were brought on board.

[jason8844]

It looks like another new examiner name is popping up not on the list. It is Suzanne Santamaria. She seems to be examining Forms from TN, GA and other southeastern states. It really looks like there are more new bodies at the NFA Branch. Will we ever see 90 day turn arounds again?

[ExecDirector]

I spoke with Clutter and there are more people coming on board, getting reshuffled, etc. New official assignments are not posted at this time. With current volume and the crush headed as a result of people flooding trust purchase applications to try and beat an undefined deadline should 41P go through, do not expect the wait times to shrink any time soon...