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FFL Watch — Compliance Checklist

NFA Item Transfer Checklist

15 items · Last updated May 4, 2026
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⚠ NEVER transfer an NFA item before ATF approval is received. Early transfer is a federal felony. Submit all forms via ATF eForms at eforms.atf.gov.
Before You Begin

Confirm the NFA item is properly registered in the NFRTR

Only registered NFA items can be transferred. Verify registration via the item's existing Form 1, 2, 3, 4, or 5 documentation before initiating any transfer.

Determine the correct transfer form type

Form 1: make/register · Form 3: FFL-to-FFL tax-exempt · Form 4: transfer to non-licensee · Form 5: tax-exempt estate or government transfer. Using the wrong form will delay or void the transfer.

Confirm applicable tax amount (effective January 1, 2026)

$0 tax: suppressors, SBRs, SBSs, and AOWs. $200 tax still applies to machineguns and destructive devices. Confirm tax category before collecting payment.

Form 4 — Transfer to Non-Licensee

Submit via ATF eForms (eforms.atf.gov) — not paper

Paper Form 4 submissions now have multi-year processing times. eForms submissions are processed in days to weeks. Paper is effectively obsolete for routine transfers.

Collect buyer's fingerprints and passport-style photo or copy of photo ID

Required for all individual Form 4 transfers. Fingerprints must be on FD-258 cards or submitted electronically if supported by your eForms workflow.

Run background check to confirm buyer is not a prohibited person

A standard NICS check is required as part of the Form 4 process. Do not skip this step even if you know the buyer personally.

For trust or corporate transfers: obtain copy of trust document or articles of incorporation

Trust transfers require a copy of the complete trust document. Corporate transfers require articles of incorporation. All responsible persons may need to submit fingerprints and photos.

CLEO notification: REMOVED for Form 1 (effective Jan 1, 2026); STILL REQUIRED for Form 4 / Form 5 (pending NPRM)

Form 1 (Make and Register): CLEO copy was removed when Form 1 was revised effective January 1, 2026 alongside the OBBBA $0 stamp form updates. Do NOT include a CLEO copy with Form 1. Form 4 (Transfer Tax Paid) and Form 5 (Transfer Tax Exempt): CLEO notification IS STILL REQUIRED today. ATF's April 29, 2026 reform package (NPRM 1140-AA65) proposes removing the CLEO requirement across all NFA forms — this is a proposed rule with public comment open and is not yet effective. Continue to send the CLEO copy with Form 4/5 submissions until the NPRM finalizes.

Do NOT transfer the NFA item to the buyer until ATF approval is received

Transferring before approval is a federal felony. There are no exceptions. The buyer may not take possession, handle, or transport the item until the approved form is in hand.

Form 3 — FFL to FFL Transfer

Form 3 must be approved before Form 4 can be submitted

The NFA item must be in the receiving FFL's inventory (Form 3 approved) before a Form 4 can be submitted for the final transfer to the end buyer. Forms 3 and 4 cannot be submitted concurrently.

Interstate Transport

Form 5320.20 still required for interstate NFA transport — submit via ATF eForms (revised form effective Jan 1, 2026)

Form 5320.20 was revised effective January 1, 2026 (alongside the OBBBA $0 stamp form revisions) and is now submitted via ATF eForms for digitized processing. Paper submissions are still accepted but significantly slower. The Form 5320.20 itself IS STILL REQUIRED before interstate transport of an NFA firearm. NOTE: ATF's April 29, 2026 reform package (NPRM 1140-AA73) proposes eliminating the advance notice/approval requirement for transport trips of 365 days or fewer — this is a proposed rule and is not yet effective. Continue to submit Form 5320.20 in advance until the NPRM finalizes.

Recordkeeping

Record NFA item acquisition in A&D Bound Book immediately upon receipt

Same-day entry required. Include: date, source, manufacturer, model, serial number, caliber, and type.

Record NFA item disposition in A&D Bound Book within 7 days of transfer

Include: date transferred, transferee name and address, and the approved form number.

Retain all NFA registration documents chronologically at licensed premises — never release originals

Form 1, 2, 3, 4, and 5 originals must remain at your licensed premises in chronological order. Provide the buyer with a copy of the approved transfer document only.

Advise buyer to retain proof of registration and make it available to ATF upon request

The NFA requires registered item owners to produce proof of registration on demand. A buyer who cannot produce their approved form is in violation.