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.
It is substantially similar. We expect there are going to be some issues to work out as we head toward the 180 unveiling. The RP thing is a big item right now and needs clarification. Our first recommendation was that an RP (or RP's) be designated just like an FFL.
Jeff Folloder
NFATCA Executive Director
www.nfatca.org