If you own or are considering an NFA trust for suppressors, short-barreled rifles, or other National Firearms Act items, understanding the fingerprint requirements is essential. The 2016 Rule 41F fundamentally changed how trusts are processed.
In This Guide
What Is an NFA Trust and Why Use One?
An NFA trust is a revocable living trust created specifically for owning NFA-regulated firearms. Unlike individual ownership, a gun trust allows multiple trustees to possess trust-owned items.
Key Benefits of Using an NFA Trust
- Multiple Authorized Users: Any trustee can possess and use items without the registered owner present
- Simplified Inheritance: Items remain in the trust; successor trustees assume roles without new transfers
- Privacy Considerations: Trust structure provides separation between individual and registration
- Flexibility: Trustees can be added or removed as circumstances change
- Protection from Accidental Violations: Properly drafted trusts help prevent unauthorized possession
The 41F Rule Change and Its Impact
Prior to July 13, 2016, NFA trusts could be submitted without fingerprints or photographs. Rule 41F changed this by requiring every "responsible person" to submit:
- Two completed FD-258 fingerprint cards (or EFT equivalent)
- A passport-style photograph
- ATF Form 5320.23 (Responsible Person Questionnaire)
- CLEO notification sent to local Chief Law Enforcement Officer
Important: If your trust has five responsible persons, you must submit these documents for all five people with every Form 1 or Form 4 application.
Who Qualifies as a Responsible Person?
ATF Definition
A responsible person is any individual with power to direct the management and policies of the trust as they pertain to firearms:
- Settlors/Grantors: The person who created the trust
- Trustees: Anyone named as a trustee with authority over trust assets
- Beneficiaries with Control: Beneficiaries with power to possess or dispose of trust firearms
Who Is NOT a Responsible Person
- Contingent Beneficiaries: Future beneficiaries with no current rights
- Minor Children: Beneficiaries under 18 who cannot legally possess NFA items
- Successor Trustees: Individuals named to take over only upon death or incapacity
- Trust Protectors: Individuals with limited administrative powers
How Many Fingerprint Cards Does Each Person Need?
Each responsible person must submit two complete sets of fingerprints with every application:
- 1 responsible person: 2 fingerprint cards
- 2 responsible persons: 4 fingerprint cards
- 3 responsible persons: 6 fingerprint cards
- 5 responsible persons: 10 fingerprint cards
Example: A trust with three responsible persons submitting five Form 4 applications in a year would need 30 total fingerprint cards (2 cards x 3 persons x 5 applications).
Fingerprint Requirements When Adding or Removing Trustees
Adding New Responsible Persons
- Formally add to the trust through a proper amendment
- Complete ATF Form 5320.23
- Obtain fingerprints on two FD-258 cards
- Have a passport-style photo taken
Removing Responsible Persons
Once properly removed through a trust amendment, that individual does not need to submit fingerprints with subsequent ATF submissions. Items already registered remain with the trust.
Individual vs Trust Application Comparison
Individual Application
- Only the single applicant submits fingerprints
- Two FD-258 fingerprint cards required
- One passport photo needed
Trust Application
- Every responsible person must submit fingerprints
- Two FD-258 cards per responsible person
- Each responsible person needs a passport photo and Form 5320.23
- Copy of trust documents must be included
Fingerprint Cost Comparison
Note: As of January 2026, the $200 NFA tax stamp has been eliminated.
- Individual (traditional): $35 fingerprinting
- Trust (3 persons, traditional): $105 fingerprinting (3 x $35)
- Trust (3 persons, SlapEFT): $30 total (3 x $10)
How SlapEFT Makes Trust Fingerprints Affordable
The SlapEFT Advantage
- Just $10 Per Conversion: Each responsible person's fingerprints converted for a flat $10
- Fast Turnaround: Receive EFT files within 24 hours
- Simple Process: Scan or photograph your cards, upload, and download your files
- Quality Guaranteed: Automated checking ensures prints meet ATF standards
Cost Savings Example
A trust with four responsible persons submitting three applications:
- Traditional: 4 persons x 3 applications x $35 = $420
- SlapEFT: 4 persons x 3 applications x $10 = $120
- Savings: $300
Save on Trust Fingerprints
Convert your FD-258 cards to EFT format for just $10 per person. Perfect for trusts with multiple responsible persons.
Convert NowFrequently Asked Questions
Do I need new fingerprints for every NFA application?
Yes. Each Form 1 or Form 4 requires fresh fingerprint cards for every responsible person. Previous submissions do not carry over.
Can I use the same EFT file for multiple applications?
No. Each application requires its own fingerprint files.
How long are fingerprint cards valid?
Cards do not technically expire, but the ATF prefers recent prints. Cards completed within the past year are generally acceptable.
Can I roll fingerprints at home for NFA trust applications?
Yes. You can purchase ink pads and blank FD-258 cards to complete fingerprints at home. Ensure prints are clear and legible.
Do minor children in the trust need fingerprints?
No. Minors cannot legally possess NFA firearms and are not responsible persons until reaching legal age and receiving possessory rights.
Conclusion
The NFA trust fingerprint requirements from Rule 41F added significant paperwork to the trust application process. Every responsible person must submit two fingerprint cards, a photograph, and Form 5320.23 with every application.
Understanding who qualifies as a responsible person and how many cards are needed helps you plan accordingly. Services like SlapEFT make compliance affordable by converting your FD-258 cards to EFT format for just $10 each.
