Justification for No Material/Nonsubstantive Change

Supplemental Document: Justification for a no material/non-substantive change

ATF requests the following changes to ATF Form 4 (5320.4):

1. As a result of the establishment of the National Firearms Act (NFA) Division, references to the ‘Branch’ are changed to ‘Division’ in the following locations:

   1. Mailing address on the face of the form (all copies)

   2. Information for the Chief Law Enforcement Officer (after item 12)(all copies)

   3. Important Information for Currently Registered Firearms (after item 20) in the first, second, third and sixth sections (all copies)

   4. Instruction 2.m

   5. Instruction 3

   6. Instruction 4 (twice)

   7. Instruction 5

   8. Instruction 6

   9. Instruction 8

2. Item 15 (photograph) – the photograph is not required on the CLEO copy, so item 15 should be grayed-out on the CLEO copy only

3. CLEO copy – gray-out the ATF use space at the bottom of the face of the form as there is no ATF approval of the CLEO copy which is sent as a notification.

4. Instruction 2.d, add language after paragraph title to clarify differences in what Federal firearms licensees are required to file

   1. Completion of Form (NOTE: if the transferee is a Federal firearms licensee except for a Type 03 licensee, items 12, 13, 14, 15, 16, 17, 18 nor 19 are required to be completed).

5. Instruction 2.h(4) – to further clarify who can sign the application, insert ‘or such other employee of the Federal firearms licensee as authorized by a responsible person’ after ‘a responsible person of the Federal firearms licensee’