Short ATF Form 4 Wait Times: Here to Stay?

Finally, gun owners have something to be happy about when it comes to the ATF. It seems things are finally lining up for the agency in charge of approvals for suppressor ownership. Word coming from officials at the ATF NFA Branch and within the suppressor industry are pointing to incredibly fast approval times for Form 4s, within 21 days from submission.

We all are aware of the Form 4 process and how arduous it has been in the past. With the roll-out of the eForms platform for submitting those forms, the public hoped the process would streamline and work faster. Unfortunately, for many submissions, that was the farthest from the truth. For instance, up through last year, people were lamenting the 6- to 8-month turnaround times, or longer in some cases, to get an approved Form 4 back from the ATF.

National Firearms Act Tax Stamp
ATF recently announced the “new normal” for processing times of Form 4 applications, many well under 3 weeks. (Shutterstock)

What’s changed?

When eForms first launched back in the 2010s, it was for manufacturers to submit their forms online to help speed up that side of the process. When the system went offline for scheduled maintenance for a few days, it ended up being down for nearly a decade. However, the industry always held on to the pipe dream of fast eForm Form 4 approvals.

Thankfully, with the relaunch of eForms a handful of years ago, ATF NFA seemed to focus on taking the Form 4 process from multiple months down to a few short weeks. It’s no great secret that suppressor ownership has skyrocketed in the last decade, and with no real end in sight, faster approval times for those Form 4s would open the door to more and faster ownership.

NFA Suppressor applications year over year
Suppressor ownership has increased year over year, with little movement to better processing times. With increased processing time, suppressor ownership could include less of a wait. [Photo: American Suppressor Association]
According to the National Firearms Registration and Transfer Record (NFRTR), suppressor ownership has grown from under 300,000 suppressors in the record in 2011, with a marked jump in ownership numbers for 2016 (thanks, Ruling 41F) to well over 3.6 million as of January 2024. With the growing number of suppressors in the NFRTR, how are the transfer times getting shorter? The process has a few different steps, and with the advent of eForm Form 4s, a few of the steps were sped up considerably. With a majority of Form 4 applications coming through the eForms system, things started speeding up, and it didn’t stop there.

Moving Forward

The leaders at ATF have been working closely with industry leaders and advocates behind the scenes to get a better picture of the issues and how they all can work together to make the system function more smoothly. ATF seems to have taken the input from industry, people like the American Suppressor Association, large dealers, and manufacturers, and rolled it into a smoother system, complete with usable feedback.

Part of the feedback happened last week when ATF hosted a webinar for FFL/SOT holders to help explain the eForm process, issues they are experiencing, and the exact number of Form 4 submissions currently in processing. In what can certainly be viewed as extreme transparency from the agency, the industry received a stark view of what’s been going on behind the doors at ATF, and a look into the future.

According to sources, ATF views the current Form 4 processing times of just a few weeks as the “new normal” and expects the timing to stay for transfers.

“The American Suppressor Association has actively advocated for improvements to Form 4 processing times for over a decade,” stated Knox Williams, President of the American Suppressor Association. He continued, “We’ve lobbied Congress, put pressure on the ATF Director, and worked directly with the NFA Division to streamline the process and minimize delays. By all accounts, it appears that work is finally paying off in the form of much faster turnaround times. If these improved processing times become the new normal, as ATF says they will, they deserve a tremendous amount of credit for finally bringing eForms into the 21st century.”

ATF went on to detail the transfer numbers for the last few months, with an increase of over double between December 2023 and February 2024 (from 31,438 up to 79,465). What is remarkable about those numbers is that when you look at the February number of just under 80,000 and compare it to the total number of Form 4 transfers 2023 at around 420,000, the turnaround time for approvals sped up considerably. ATF pointed out that 96% of all Form 4 transfers are dealt with through the eForms system.

ATF Form 4 transfers Novembr 23 through February 24
Suppressor transfers shot up in the month of February while processing times continued to get faster. ATF now sorts transfers into lanes for faster processing. [Photo: ASA]

Explaining the Change

ATF explained the rapid increase in turnaround timing to a change in how the agency approaches transfers. Historically, NFA had a “first in, first out” policy to transfers, meaning all the transfers were dealt with on a received date method. Hang-ups inevitably happened when a Form 4 would get delayed, thus delaying the whole batch.

With new transfers within the eForms system, NFA moves forward with any transfer that receives a “proceed” response from the FBI-NICS check. Explaining that nearly 70% of applications receive an immediate “proceed” response from NICS. A “delayed” response means that the FBI needs to investigate further because remember NFA/ATF does not handle the background portion of the application, and unfortunately these are handled by the FBI on a time-available basis after the GCA checks.

So, how is ATF NFA processing forms now? ATF explained they are utilizing different “lanes” to group similar applications. That means there is a lane for Individual applications, Individual bundling (multiple forms from the same individual), Trusts, and Trust bundling. Additionally, the agency explained that the numerous individual Form 4s are getting approved faster than those submitted using a trust, which is something they didn’t anticipate with Ruling 41F. A lot of the delays with the Trust Form 4 submissions have to do with missing information or incorrect information that requires more manpower on the NFA’s side to rectify the issues.

Remaining Issues

That being said, the new system is not without grandfathered issues. With periodic system maintenance or outages, the turnaround times can certainly vary. Not to mention the still existing backlog within the system itself. At the time of the webinar, ATF was still waiting on nearly 78,000 outstanding background checks from NICS, with the oldest being from May 2023. But they have reduced the backlog by over 35% since October 2023, so that certainly helps.

ATF Responsible Person Questionnaire
How can you help make the process fast? ATF recommends including your SSN either on the Form 4 or the RPQ (Responsible Person Questionnaire) to help eliminate delays. [Photo: ATF]
But as ATF stated on the webinar, the agency anticipates 3-week or faster turnaround times to become the expected rather than the exception. What can you do to help ensure your Form 4 gets approved quickly? ATF laid out the specifics for just that. First off, Individual Form 4 submissions are moving the fastest right now and single-party trusts should follow suit. As the transferee on the Form 4, provide your Social Security Number on either the application or the Responsible Person Questionnaire. Lastly, if a previous application of yours has been delayed, get an FBI UPIN to help reduce further delays.

All in all, the NFA at ATF seems to have taken steps in a very good direction when it comes to processing the Form 4 applications. I can’t help but wonder if the new bottleneck in the supply line won’t be the NFA but could end up being the manufacturers themselves struggling to keep up with demand. However you want to look at it, the fast turnaround times of under 3 weeks is a fabulous thing to finally see happening!

Patti Miller is one of the most awesome females in the tactical/firearm (or any) industry. Imagine a tall, hawt, dangerous Laura Ingalls Wilder type with cool hair and a suppressed blaster and you'll be getting the idea. What's interesting is that in addition to being a willing brawler and intrepid adventuress, she's also an Ent/Ogier level gardener and a truly badass baker.

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