It looks like it. I am not a lawyer, but I play one online. To me, this appears to be a good thing to the NFA community. I am not sure if in the process of trying to make it harder, the administration accidentally made it easier for individuals. Or, if what I think is the case, we actually have allies in the ATF who are sympathetic to our plight and they crafted this rule in a way to please both sides.
While many NFA people are saying they are upset, I think they should take it as a win. Especially due to the vague language of what a "responsible person" is on the trust.