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NFATCA Report: Turning Up the Heat
by John Brown

As the summer came to a close, NFA-TCA board members resumed their weekly conference calls right after Labor Day (as opposed to bi-weekly calls during the summer months). One of our board members was furious about how long transfer times were taking as the year had progressed. It was interesting to hear not only the frustration but the pure anxiety of what some of our members were actually feeling from the constant delays in processing as we all were falling victim to the slow grind of how a growing phenomenon is not being handled well by the government. In spite of the economy the number of Forms being processed by the NFA Branch continues to explode while the resources available to handle this ever growing situation seem to dwindle. At last count the NFA Branch had ten available examiners that were handling the work what would normally be staffed by twelve personnel.

With the increased work load weighing heavily on fewer people, it looks like this is a losing battle for the Branch. Ted Clutter is on top of this stack of Forms trying his best to manage the onslaught of work. With the recent change to handling Forms according to state, the NFA Branch managed to get a handle on transfers for a short period of time: however, being short on examiners insures that the tide will continue to rise.

Just how bad is this rising tide? The truth of the matter is that we are slowly approaching the one hundred thousand transfer mark faster than we expected. This means that it is likely that when ATF meets its fiscal year in October that the monthly average on Forms processed will likely exceed 9,600 forms per month. If you do the simple math this means that each examiner in the NFA Branch is responsible for approximately 50 Forms a day once you have taken out all of the holidays and other activities required in their jobs.

Form 4 transfers are taking about five months and when you look back at where we were four years ago when a Form 4 only took 22 days it is hard to believe that the processing time has deteriorated to such a point. Believe me when I tell you that the Branch team in place is bailing water as fast as they know how. We need to reach out to our congressional representatives to make certain that we support the NFA Branch with appropriate funding support to meet the increasing demands that we the industry are putting on the branch. Granted, most of you who read this article won’t make that call or write a letter to help get the NFA Branch the help it really needs. That takes time and with the economy in the state it’s in we are all busy enough. If that’s the case let us take time to remind you of some important issues that you as members of the NFA community can do to make a difference in this entire Forms processing fiasco.

When you take into consideration that the NFA Branch is still having problems with nearly 40% of the transfers that come in for processing, it’s no wonder that they have trouble keeping up with the flow. And when you consider that a lot of people are still writing bad checks, is it any wonder that transfers take so long and screw up the processing time for the rest of us? The message here is simple: this issue is as much of an industry problem as it is a Branch problem. In many articles we continue to remind our industry members to check Forms carefully in order to insure that they can be processed the first time they are submitted. Follow the instructions carefully and have your dealer make certain that he checks over everything before you send anything in for processing. Even those industries that submit dozens of Forms every week still make mistakes. Until such time we get to a complete electronic processing platform check everything twice. Just stop and think for a second how much faster and more efficient the Branch would be if we did things right the first time upon submission.

We may soon see the evolution of the Form 3, Form 5, and the Form 9 close on our heels for electronic processing. Align that with the fact that ATF is nearly ready to take on the credit card as a form of processing payment and things will certainly speed up during the coming months. Additionally, electronic Forms submission will show mistakes that are made with user error. The nice thing we have seen with the trials thus far is that you simply can’t make a mistake. If you do then you can’t move onto the next step in completing the electronic version of the Form.

The bottom line is simple. ATF and the NFA Branch is making every effort to keep up with the demand that is ever increasing with the industry with the huge increase, not in machine guns, but in SBRs, SBSs, AOWs and suppressors. There are however two critical elements that must occur in order for this to be successful and move us back to the days when Forms were processed with the speed that is reasonable and palatable. First and foremost, we as industry’s members must be diligent in our preparation of all of the forms and information that we submit to the NFA Branch. If you want to know why the NFRTR is as inaccurate as it is, you must remember one simple rule: Garbage In, Garbage Out. Many of the bad information items found in the NFRTR that are found today can easily be traced back to bad input. So be careful what you submit.

Secondly, each and everyone one of us has a responsibility to support the initiatives that agencies like ATF need in order to get the job done. Take the time today to let your local representatives know what you expect and why. With both of these efforts we can all offer the support to help the NFA Branch reach the goals necessary to provide the type of customer service that we are all expecting.

And in addition to all that, come and support the NFATCA in its efforts to bring positive change to how the industry and ATF work together. Join us and help the entire industry make the difference in a positive way. Contact us today at www.nfatca.org

This article first appeared in Small Arms Review V15N3 (December 2011)
and was posted online on November 1, 2011

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