Suppressor sales have grown significantly as more states have legalized suppressor ownership. For FFL dealers who sell suppressors, the compliance requirements are more involved than standard retail transfers.
The NFA Transfer Process
Suppressors are NFA items subject to the National Firearms Act. Every suppressor transfer from a dealer to an individual requires ATF approval via Form 4 and payment of the $200 transfer tax. Current Form 4 processing times vary significantly — buyers should be advised to expect a wait.
Form 4473 Is Still Required
The ATF approval of the NFA transfer does not substitute for the Form 4473. When the approved Form 4 is returned and the buyer comes in to take possession, a Form 4473 must be completed and a NICS check conducted at that time.
The Form 4473 is completed at pickup, not at purchase. This is the most common timing error in suppressor transfers. The Form 4473 documents the transfer — and the transfer does not occur until the buyer takes possession with an approved Form 4. Complete the 4473 at that moment.
Trust and Entity Transfers
Many suppressor buyers purchase through an NFA trust. When the transferee is a trust, the Form 4473 is completed by the responsible persons of the trust. Each responsible person who will possess the suppressor must complete a Form 4473.
State Restrictions on Suppressors
Suppressors are legal to own in most states but remain prohibited in a handful. Before transferring a suppressor, verify that the buyer's state of residence permits suppressor ownership. Transferring to a resident of a state where suppressors are prohibited is a serious federal compliance violation.
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