Last I heard, every Responsible Person will have to submit pics/prints/questionnaire for every new stamp application, only exempting unaltered trusts from submission for 2 years from last submission, though it appeared this is in contradiction to the plain language of the rule.

Is this still the lawyers' consensus and guidance from the ATF?





Is there any clarity as to whether a Co-Trustee can be restricted to mere authority to possess NFA items but not given administrative authority and would thereby be exempted from RP status and obligations by failing the two-pronged test for RP status?


If the above limited authority avoids RP status for a Co-Trustee, is there any clarity as to whether a Successor Trustee can be designated as such a limited Co-Trustee while the Primary Trustee/Settlor is alive/capable, thereby exempting the Successor from RP status until the death or incapacity of the Primary/Settlor?

What about a Beneficiary who is not given authority to possess or administer except upon death or incapacity of the Primary/Settlor?