Q: In reference to the solution 10979, I am concerned about one sentence in this solution. Specifically, ?Remember that ATF requires FFLs use a Form 4473 and conduct a NICS/background check on all silencer transfers whether to a trust or not.” – I have completed a Form 4473 for ALL NFA transfers. – I have also conducted NICS/background checks for ALL TRUST transfers. (or accepted a valid concealed handgun license) – On three silencer transfers to INDIVIDUALS (not trusts) I have marked the box in block 22 ?No NICS check was required because the transfer involved only National Firearms Act firearm(s).? This would seem to be in conflict with the statement in the solution ? i.e. ?whether a trust or not.? This is also different than advice I?ve gotten from our local ATF Industry Operations Inspector Connie Rice ? when she was providing guidance on filling out 4473?s for NFA transfers. – On one SBR transfer to an individual, I have marked block 22 instead of conducting the background check. I understand that I must complete a background check on any NFA item being transferred to a trust, but my understanding is, for any NFA item (including silencers) being transferred to an individual, I can simply mark block 22. Is that understanding incorrect? If so, what must I do about it?
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