NFA- "Declaration of Trust" WTH?

[Climber]

I submitted my form 4 over 6 months ago and just got back a denial letter stating the following:

Declaration of trust is required, including any attachments mentioned in the trust.

 

I spoke to my dealer, my attorney and the NFA and no one seems to know exactly what is required!  To the best of my understanding, the NFA now wants a schedule of assets that lists everything currently in the trust.  This is my 3rd class 3 item and I have never gotten this letter and an internet search turned up nothing definitive.  Have yall ever heard of this?  I'm unclear on what I need to send them.

 

Thanks!

BTW- I assume this is another "stall" procedure as I have a trust.   I came really close to terminating my application as I'm so PO'd about this entire process.

[cannoncocker]

Did you enclose a copy of your trust with the F4 submission in question?   I was told subsequent submissions did not require the trust, but always included a copy.  A Declaration of Trust is nothing more than a document evidencing the trust exists.  My trustees each have a notarized Declaration, but I never submitted a copy of the Declaration of Trust to the BATFE.

 

Does your trust require a listing of assets?  Mine does not.  However, each class III item I submitted was assigned to the trust on a single assignment form attached to the F4.

 

Perhaps you ran into an inexperienced pre-examiner.

[Guest 6.8 AR]

But, but, "They can do that!!!"

[Hershmeister]

Call them

[Climber]

Yea, I did call them and was given the run around.  Talked to Mr. Thurston at 08.

I included all required docs: trust, assignment form, form 4, cert of compliance, blah blah blah.

 

I get the feeling they are just really starting to crack down on trusts.  I would probably go a different route if I ever do this again which is very doubtful.  Its just not worth the hassle.  But then again, that is exactly what they want!  On second thought, I think I'm going to go SBR something this week :)

[whitewolf001]

Yea, I did call them and was given the run around.  Talked to Mr. Thurston at 08.

I included all required docs: trust, assignment form, form 4, cert of compliance, blah blah blah.

 

I get the feeling they are just really starting to crack down on trusts.  I would probably go a different route if I ever do this again which is very doubtful.  Its just not worth the hassle.  But then again, that is exactly what they want!  On second thought, I think I'm going to go SBR something this week :)

 

Ever since I heard about that Exec Order from der Fu... er President, I had a feeling something like this would happen.

[csaxj3]

Must have done something wrong.

Dozens of eForm 1 and 4's are getting approved at the 90 day mark.

Have your dealer efile the form 4 and thank me later.

[midtennchip]

The ATF hired several new examiners and made some other moves in the West Virginia office. We were not seeing these issues before the new hires started working trust applications. My opinion is that a number of these problems stem from new examiners who just are not familiar with trusts. Different states have different terminology for legal documents and trusts are no exception. The term "declaration of trust" is just another name for the trust document. We just don't typically use that title in Tennessee. But if an examiner has been looking at "declarations of trust" and then sees one without that title, there's a good chance of a problem popping up simply because of inexperience.

Add to that the current negative environment within the ATF.