The American Suppressor Association (ASA) would like to thank NASGW and its members for your support. For those that may be unfamiliar with the ASA and its mission, it is the unified voice of the suppressor industry. Its mission is to unite and advocate for the common interests of suppressor manufacturers, distributors, dealers, and consumers. To accomplish this mission, its principal initiatives focus on state lobbying, federal lobbying, and public education.The ASA is the country’s leading subject matter experts on suppressors and suppressor related advocacy. It has helped draft state and federal legislation, including the Hearing Protection Act, hosted countless suppressor demonstrations for legislators, is spearheading efforts to legalize commercial suppressor exportation through non-legislative means, and has actively lobbied in 28 states, as well as in Washington, D.C.Earlier this year, ASA Executive Director, Knox Williams, Director of Outreach, Owen Miller, and representatives from ASA member companies met with BATFE executive leadership. The ASA made an information request for updated registration and transfer statistics on National Firearms Act (NFA) firearms from ATF. ASA combined this information, along with information published in the ATF’s annualFirearms Commerce in the United Statesreports to form its analysis. Suppressors account for approximately 82% of the tax-paid transfer applications received and processed by the NFA Division in 2017. This provides a fairly accurate barometer of suppressor sales across the industry.
As a result of the implementation of ATF Rule 41F on July 13, 2016, approximately two years’ worth of consumer purchases were compressed into the first 6 months of 2016. In stark contrast, 2017 rebounded as a relatively “normal” year, with the total number of Form 4 applications submitted falling in between 2014 and 2015 levels. The NFA Division processed 184,282 Form 4 applications in 2017 – about 74,000 more applications than they received. However, it continues to have a backlog of over 58,000 pending Form 4 transfers.Prior to 41F, approximately 89% of transfers were submitted by legal entities/trusts. Following the implementation of the new rule, the NFA Division anticipated an inversion of that trend to 25% trust and 75% individual applications. That prediction did not come to fruition. As it stands, transfers currently breakdown to roughly 48% trust vs. 52% individual applications.Individual applications were being processed at a much faster rate than trust applications, largely because ATF reviews every trust, and every responsible person listed on a trust now must have a background check. With multiple responsible persons on a trust, there is a higher probability for errors or lengthy background check delays, adding to the already unreasonably high wait times. This disparity in transfer times is beginning to converge and level off at about five months for approval.
The Top 5 most common errors for Form 4 applications are as follows:
Missing photographsFingerprint cards incomplete (information blocks not filled out such as applicant SSN)
RPQ forms – None submitted, too many/not enough compared to trustees listed
Trust/Individual names do not match on forms
Missing transferor (dealer) signature/date
In the case of trust applications, an error on any one of the RPQ forms, a missing RPQ form, an RPQ received for a trustee not listed in trust documents, or a background check delay or outright denial will delay the entire transfer.ATF also provided updated manufacturing registration numbers for suppressors. As of December 31, 2017 there were 1,378,289 suppressors registered in the National Firearms Registration & Transfer Record (NFRTR). Those suppressors are distributed as follows:
Suppressor Distribution in the NFRTR:
Individual: 197,377Trust/Legal Entity: 494,202FFL/SOT: 612,332Gov/LE/MIL 74,378 Total 1,378,289
Based on ASA’s analysis, in the five years from 2011-2015 an average of 123,544 suppressors were produced each year. For the 14 month period of February 2016 to April 2017 over 457,200 suppressors were manufactured from the announcement of ATF 41F through April 2017. However, just 356,342 Form 4s were received during the same period. This left a manufacturing excess of just over 100,000 suppressors made vs. sold in 2016 and early 2017. The last eight months of 2017 saw just 18,266 suppressors manufactured, while 66,885 Form 4’s were received by ATF. This significant slowing in manufacture of new suppressors has begun to clear out the over-supply problem that distributors and dealers have faced. This condition is not unique to the suppressor market; it has been a common theme throughout the firearms industry in 2017.The ASA has already begun working on legislative and regulatory means to reduce the transfer times as quickly as possible. While we will continue our educational push for suppressor deregulation, our top priority for 2018 is wait time reduction. For more information, visitwww.AmericanSuppressorAssociation.com.
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