In December 2021, the ATF announced a modernized relaunch of the ATF eForms platform. A long time coming, the update would provide better services to industry members, trade associations, and the public by reducing the effort and time required to review and process applications. More importantly, the system update would bring back the eForm 4, or “Application for Tax Paid Transfer and Registration of Firearm,” used to request approval to transfer an NFA firearm, notably suppressors.

For years, only paper ATF Form 4 applications could be filed, leading to long and inconsistent processing times dragging over 12 months despite contradicting the 8-month “average” noted on the ATF’s website – the longest of any paper application, and three months longer than any other form. However, with the relaunch of the new system and eForm 4, the ATF had stated its aim was to process new applications within 90 days. A lofty goal, FFLs and gun owners alike expressed their doubts.

Now three months later, reports from across the firearms industry indicate the ATF is meeting its mark in most cases. Not only have many of the first eForms 4 filed been approved in less than 90 days, but many have been processed within 60 days, and others reportedly within just a week.

Industry Reports
“Numerous Silencer Shop customers have already received their eForm 4 approvals. Per the ATF, the timeline was an expected 90 days, and some customers have been approved much sooner. We’ve seen applications submitted on Jan 17, 2022 approved on February 11, 2022, which is less 30 days and we’ve even seen a 6 day approval,” said Dave Matheny, Silencer Shop CEO.

“We have always been committed to making buying silencers simple for our customers but with a turnaround time from the ATF under 90 days, we can now do that in record time,” said Silencer Central CEO, Brandon Mattox. “This approval was received within the promised 90-day timeframe for a customer in Oklahoma. Setting a precedent for future eForm applications, this process has ensured that Form 4 submissions arrive at the ATF instantaneously and are ready for the approval process.”

Using customer data submitted on their website, as well as that posted on the 150,000-member Reddit r/NFA subreddit, National Gun Trusts compiled the average approval time of ATF eForms 4 for individuals and gun trusts, as well as by state. For individuals, the average eForm 4 was processed in 57 days, while gun trusts were processed in 50 days – a disparity often reversed. This is compared to 183 days and 229 days, respectively, for paper applications.

Of 18 states with data, 17 averaged exactly 90 days or fewer for eForms 4, with five averaging less than 50 days. And though it’s unknown how many data points have been submitted for each state, the numbers are impressive given what gun owners were waiting only a few months ago.

Suppressor Growth
Between April 2020 and May 2021, suppressors registered in the National Firearms Registration and Transfer Record (NFRTR) increased 30% to more than 2.6 million, according to the ATF’s 2021 Firearms in Commerce Report. This year’s numbers are not yet available, but the number of silencers is expected to continue to grow as more manufacturers join the market, more options hit dealer shelves, and shorter eForm 4 wait times encourage more gun owners to purchase the sound devices.

For how to manage your NFA firearm inventory, navigate ATF eForms, and speak with ATF executives and personnel about the latest updates and regulations, register to attend the 2022 Firearms Industry Conference (FIC), where policymakers, attorneys and subject matter experts will lead virtual and in-person learning sessions on April 21–27.

FFLs are also encouraged to contact Orchid’s trusted in-house legal and compliance professionals to learn more about the proper manufacturing, storage and selling of suppressors and other NFA firearms.

UPDATE

Since publishing this article, ATF has updated various ATF Form processing times on its website.  The average processing time for eForms 4 is now listed as 100 days.