Your Privacy Choices
Good evening everyone and welcome back to TFB’s Silencer Saturday brought to you by Yankee Hill Machine, manufacturers of the brand new YHM 338 Bad Larry Suppressor. Last week we pulled out an old favorite – the MK12 and the Allen Engineering AEM5 .223 suppressor. This week we are going to discuss the ATF eForms update and some upcoming suppressor projects for 2024. Let’s get to it.
TFB’s Behind the Gun Podcast (I always bring up silencers):
- TFB Behind The Gun Podcast #106: Talking Shop With Savage Arms’ Beth Shimanski
- TFB Behind The Gun Podcast #105: The Future of DIY Firearms with Open Source Defense
- TFB Behind The Gun Podcast #104: Andrew Wright with SureFire
SILENCER SATURDAY #318: ATF eForms Update, Upcoming Suppressor Projects
The 2024 Silencer Saturday review season will kick off shortly; we are on a brief administrative pause while I await my FFL renewal application approval and a stop-gap Letter of Authorization that will allow us to continue to process NFA Form 3 transfers. It’s my own fault – apparently I messed up the credit card number in the payment section which caused the delay. The check, as they say, is in the mail.
Our federal firearms laws leave a lot to be desired and range from confusing at their best to blatantly unconstitutional at their worst. Through legislation, I hope that I live long enough to see the end of laws like the National Firearms Act (NFA) that regulates barrel lengths and silencers, as well as the outright ban of the making and ownership of machine-guns manufactured after 1986 by ordinary citizens. In fact, I don’t take it lightly when I test a new suppressor for full-auto capabilities, knowing that 99.9% of the population are priced out of a finite supply of pre-1986 machine guns.
On the other hand, my interaction with the ATF at the administrative level has always been positive, or at least on par with other customer-facing government agencies. My FFL application process was smooth, my questions through via ‘Ask The Experts’ on the NFA eForms portal have been timely and helpful, and Form 3s have only taken a day or two. I’m guessing I will get labeled as an apologist or boot-licker, but most of our issues are with the laws of the land and not the individuals behind the machine.
Although, the interpretation of some of the laws and how to enforce them by certain agencies can be cause for concern. I discussed this topic with the guys at Open Source Defense (OSD) in a recent Behind The Gun Podcast.
Common ATF terms and abbreviations:
- NFA – National Firearms Act: A 90 year old law that regulates the transfer, making, manufacturing, and sale of controlled items such as short barrel rifles, silencers, and machine-guns. Link: https://www.atf.gov/rules-and-regulations/national-firearms-act
- FFL – Federal Firearms License: Required for individuals or entities that are engaged in the business of transferring, sales, or manufacturing of firearms. The FFL application: https://www.atf.gov/file/61506/download
- SOT – Special Occupational Taxpayer: A tax stamp required for FFL holders to manufacture, transfer, or sell NFA controlled items via a tax-paid exemption. The SOT application: https://www.atf.gov/firearms/docs/form/special-tax-registration-and-return-national-firearms-act-atf-form-56307/download
- ATF Form 1: An application to make an NFA controlled item by a non-license holder by paying $200 and receiving a tax-paid stamp. The actual form: https://www.atf.gov/firearms/docs/form/form-1-application-make-and-register-firearm-atf-form-53201/download
- ATF Form 4: An application to transfer an NFA controlled item from a license holder with an SOT to a non-license holder by paying $200 and receiving a tax-paid stamp. The actual form: https://www.atf.gov/firearms/docs/form/form-4-application-tax-paid-transfer-and-registration-firearm-atf-form-53204/download
- ATF Form 3: An application to transfer an NFA controlled item from a license holder with an SOT to another license-holder with an SOT without having to pay for a tax stamp. The actual form: https://www.atf.gov/firearms/docs/form/form-3-application-tax-exempt-transfer-firearm-and-registration-special/download
- ATF eForms System: A web-based application to submit NFA applications/forms and receive approvals in lieu of submitting paper forms. Link: https://eforms.atf.gov/
Earlier this week a concerning rumor was floating around that the ATF eForms system was halted due to budget constraints, which would have a significant impact on individuals and companies. While the government can and will make illogical decisions, I wasn’t quite ready to sound any alarms over the system outage.
Ammoland: ammoland.com/…/atf-eforms-system-shut-down-claims-budgeting-concerns
Thankfully, I received an email yesterday, like all of the other users, stating that the eForms system was back up and running. Whether the shutdown was actually for budgetary issues or some sort of maintenance required on an antiquated piece of hardware, we may never know. But I’d put my money on the latter explanation being the most plausible.
SILENCER SATURDAY #318: ATF eForms Update, Upcoming Suppressor Projects
Speaking of eForms and NFA processing times, there have been some positive developments in the last few months in terms of approval wait times. The Form 1 approval times are looking much better than previous years. The official approval times from the ATF are posted below.
Current NFA Processing Times – As of Feb. 1, 2024
Source: https://www.atf.gov/resource-center/current-processing-times
ATF Form Paper eForms
Form 1 – Application to Make and Register a Firearm 85 days 47 days
Form 3 Application for Tax-Exempt Transfer (SOT) 17 days 11 days
Form 4 Application for Tax Paid Transfer – Trust 270 days 224 days
Form 4 Application for Tax Paid Transfer – Individual 243 days 196 days
But there are also a growing number of Form 4 approvals that are occurring in days or weeks instead of months. I saw a seven day approval yesterday and Twitter/X has a selection of fast approvals as well.
Again, setting aside the fact that the NFA shouldn’t exist, that any wait for an approval to own a silencer is too long, and other constitutional declarations, having NFA application wait times drop significantly is good for both consumers and the industry. Waiting hurts increased adoption, which ultimately slows innovation by manufacturers. My advice to everyone who is thinking about buying a new silencer is to not time the market, just get the process started.
Upcoming Projects:
8.6 Blackout
As much as it pains me to have to buy and stock a new caliber, I need to find out more about the excitement behind 300 Blackout’s big brother, 8.6 Blackout. We have four 8.6 silencers heading to Silencer Saturday for review, so my plan is to build a bolt action rifle off of the new Aero Precision Solus platform. I will be wading into uncharted waters, so I could use some advice on the rifle, ammo, and possibly hand-loading to keep costs more reasonable. Post your comments below or email me at pete@thefirearmblog.com.
Allen Engineering – Bolt Action Hosts
I worry that I am turning into a Fudd with my recent bolt action rifle obsession, but after last week’s range session with the MK12 and the AEM5, I have decided it is time for two dedicated builds. The first is a 5.56 bolt gun host with a barrel profiled to accept an Allen Engineering suppressor. The second build is identical to the first except with a host rifle chambered in .308 with a .30 caliber AE suppressor. Although I am not going for a clone-correct build, the below M24 rifles will serve as inspiration for the builds. Again, advice is welcome.
SILENCER SATURDAY #318: ATF eForms Update, Suppressor Projects -M24A3 – Credit: Allen Engineering
SILENCER SATURDAY #318: ATF eForms Update, Suppressor Projects – M24A3 Credit: Allen Engineering
Thanks for reading. Be safe, have fun, and we’ll see you next week for another Silencer Saturday.
