Last Fall, the Obama Administration issued an executive action that seeks to amend the transfer of NFA firearms. Known as ATF 41P, it was published in the Federal Register on September 9 and granted a 90 day comment period. In all, over 9,500 comments were submitted to the Federal Register. Of those, around 1,000 were disqualified for vulgarity, anonymity, or non-applicability. Not surprisingly, the overwhelming majority of comments were in opposition to the proposed CLEO signoff requirement. The ASA comment can be viewed here: ASA Comment

The standard timeframe for a final ruling is generally six months after the close of the comment period. However, because of the overwhelming amount of comments submitted, we were told by ATF that the final ruling would likely not be issued until early 2015, because each qualified comment must be responded to by the ATF in writing. This was recently confirmed by an update in the latest publication of the Semi-Annual Regulatory Agenda.

After the final ruling is issued, there are generally 60 days before implementation. Until the ruling is released, we will not know if forms that are already in the transfer process will be exempt from the proposed requirements. However, if history is an example, it is likely that all forms received by the ATF prior to the implementation of the final regulation will be exempt.