News from Reeves & Dola, LLP 
*** R|D ALERT ***

ATF POSTS NEW PROCESSING TIMES FOR APPLICATIONS AND VARIANCE REQUESTS

The Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) recently posted new processing times for National Firearms Act (NFA) transfer applications, Gun Control Act (GCA) license applications, and explosives applications.  Processing times of most interest to firearms industry members are the following:

ATF Form 3 
 2 months
ATF Form 5
 1 month
ATF Form 9
 1 month
Marking Variances
 3 months
Form 6
 6 weeks

In addition, the current processing time for ATF Form 4, Application for Tax-Paid Transfer and Registration of Firearms, is six months. Industry members may recall that within the past two years processing time for this form was as high as ten months. The decrease in processing time is attributable to ATF's recent hiring of more Examiners to process NFA registration and transfer documents. However, ATF officials advise the agency has received hundreds of thousands of transfer applications during the months of May and June as industry members try to avoid the requirements of recent regulatory changes.  The changes to 27 C.F.R. Part 479 (announced in our Alert of January 13, 2016), require that all responsible persons of trusts and legal entities such as partnerships and corporations submit photographs and fingerprints when the entity submits an application to make or transfer a firearm subject to the National Firearms Act. Previous regulations allowed the transfer of NFA firearms to trusts and other legal entities without any photographs and fingerprints. The new requirements became effective on July 13, 2016, and ATF has been deluged with transfer applications submitted under the old requirements. It is likely that processing times for Forms 4 (and potentially other NFA forms) will increase with application volume.  
 
The u pdated information on ATF's website indicates the processing times indicated are those applicable to paper forms only. Processing times may be significantly less for electronic forms.  Information on ATF's eForms is available on the ATF website .

The above alert is for informational purposes only and is not intended to be construed or used as legal advice. Receipt of this alert does not establish, in and of itself, an attorney-client relationship.    

Questions about this alert can be directed to: 

Johanna Reeves:   202.715.9941  | jreeves@reevesdola.com
Teresa Ficaretta:      202.715.9183 |  tficaretta@reevesdola.com
Katherine Heubert:  202.715.9940  | kheubert@reevesdola.com

About Reeves & Dola

Reeves & Dola is a Washington, DC law firm that specializes in helping clients navigate the highly regulated and complex world of manufacturing, sales and international trade of defense and commercial products. We have a deep understanding of the Federal regulatory process, and use our expertise in working with a variety of Federal agencies to assist our clients with their transactional and regulatory needs.

Reeves & Dola, LLP
1775 Eye Street, NW, Suite 1150
Washington, DC 20006
202.683.4200