Q: Last year one of the two owners of our company bought out the other owner and as a result we had to apply for a new FFL with the now sole owner as the only listed RP. Over the year since we have been working to have ATF approve Form 3s transferring our NFA inventory including post sample machine guns to our new license and the final Form 4s issued to customers. We are close to completing this process and only have one Form 3 awaiting approval for two post sample machine guns, but today the local ATF office called asking us to surrender the original license due to the amount of time it’s been outstanding. In order to expedite this the local ATF IOI is now telling us that we do not need Form 3s approved transferring our NFA inventory from one FFL to the other since our EIN has not changed just the FFL # and to just transfer the remaining two post sample machine guns with disposition entries in our A&D and no Form 3.
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