NFA Item Transfer Checklist — SOT Dealer Compliance

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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 is no longer required for individual Form 4 transfers

The CLEO copy requirement was removed effective January 1, 2026. Do not include it — the form has been updated to reflect this change.

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

Use ATF's digitized Form 5320.20 process for interstate NFA transport (effective January 2026)

The new digital process replaced the previous paper-based mailing system. Submit via eForms. Paper Form 5320.20 is still accepted but significantly slower.

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.