Nicely done. I only take exception to your number 1 review. I feel confident that just as an FFL holder can list responsible persons that do not include *every* person, so will trusts and corps. For instance, the trust could list the current trustees as responsible persons and not the beneficiaries. And that list could change over time. I suspect a new form in the offing. And with that said, I'm not sure how ATF intends to regulate this. Let's say I add my daughter to the responsible person list. She's already a trustee and beneficiary on the trust document, but I choose not to make her responsible until she is 21. She becomes 21 and I add her. She's technically already able to possess by the trust, but I assume there is going to be some waiting period while NFA Branch "approves" the addition and notifies us. Or maybe not!

I could also see this going the way of barrel length change notifications on SBR's. All you do is notify ATF and you only get an acknowledgement if you request one. I just don't know. It's a very kludgy, unwieldy mess that is coming, no matter what.

As for the CLEO notification: consider that a political sop. CLEO's already had the ability to keep store and codify this data before. This doesn't go away. This, from what I understand, was the trade advocated by the Sheriff's Association: CLEO's give up the signature process and get blanket notification without having to participate as a gatekeeper. Many CLEO's hated being the gatekeeper because their opponents used it as a club in elections. Now EVERY CLEO is on an equal footing.

As for storage of the information, again, I suppose they could and always have been able to do it, but... There is no federal funding to provide for storage of the records. And I seriously doubt that in this day and age that many jurisdictions are going to allocate much additional funding for a "new" record keeping program caused by the feds. I could be wrong.