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ATF is proposing to remove the CLEO notification requirement from the NFA process, which could finally kill one more pointless paperwork headache for suppressors, SBRs, SBSs, AOWs, machine guns, and other NFA firearms.
Table of contents
- The NFA Permission Slip Problem May Finally Be Ending
- Why Collectors Hated The Old CLEO Signature System
- ATF’s New NFA Proposal Takes Aim At CLEO Notification
- What Removing CLEO Notification Would Actually Change
- Comment Deadline For The ATF CLEO Notification Rule
- The Bottom Line For NFA Applicants
- Related Reads From GunsAmerica Digest
The NFA Permission Slip Problem May Finally Be Ending
The National Firearms Act (NFA) regulates machine guns, Short Barreled Rifles (SBR), Short Barreled Shotguns (SBS), Silencers, Destructive Devices, and Any Other Weapon with a process of registration and taxation. While the tax aspect was removed from SBR, SBS, Silencer, and AOW activities in 2025, the registration aspect remains intact for all categories. Until 2016, the process required the signature of a Chief Law Enforcement Officer, commonly referred to as the “CLEO”, having jurisdiction over the applicant’s address. Those licensed to engage in the business of NFA firearms were exempt.
That CLEO signature requirement was almost universally hated in the collector world, and for good reason. Many applicants were denied access to these firearms for reasons beyond their control and not related to any misconduct on their part. Some CLEOs were ideologically opposed to ownership of such firearms, and others were genuinely worried about being blamed for someone else’s misuse of the firearm and having that signature used against them.
Why Collectors Hated The Old CLEO Signature System
My first trip to the sheriff for this “permission slip” fell into the second category. As he signed the form, he said, “Please don’t do anything stupid with this,” and it was easy to tell his worry was genuine. Here was someone he had never met, with no knowledge of, asking for his name to be associated with a machine gun acquisition and text in the certification regarding him having no knowledge that I would misuse the firearm. Over the years, a few lawsuits were attempted to address this extraconstitutional restriction, but were unsuccessful.
The first step in reforming this constraint took effect in 2016 when ATF, acting on a petition from the National Firearms Act Trade & Collector’s Association (NFATCA), updated the regulations to require a CLEO notification instead of a signature. While a significant improvement, it was still a hassle and left some discomfort with some applicants. How do you prove you delivered it? If you mailed it, are you responsible for a lost or misplaced letter? How do you prove delivery if you did so in person?
ATF’s New NFA Proposal Takes Aim At CLEO Notification
Now, in the current proposed regulation change, this impediment may finally be a thing of the past in its entirety. ATF cited multiple reasons for removing the CLEO notification requirement. All seem very logical and unsurprising:
- ATF has no information that the CLEO notification meaningfully aids criminal investigations or serves a significant purpose for local law enforcement. Additionally, ATF does not need the notices for purposes of approving or disapproving firearm transfers.
- All applicants to make or transfer NFA firearms are subject to a thorough background check through the National Instant Criminal Background Check System.
- ATF makes its own assessment of state and local law to determine whether specific NFA firearms are lawful in the maker’s or transferee’s jurisdiction and no longer relies on local law enforcement for that information.
- In the nearly ten years this system has been in place, it has not worked as intended. During this time period, ATF is not aware of CLEOs performing independent background checks or filing objections to making or transferring a firearm. The general feedback to ATF regarding the CLEO notification has been that law enforcement agencies simply discard these notices.
What Removing CLEO Notification Would Actually Change
If approved as proposed, the implementing regulations of the making and transfer applications, 27 CFR 479.62 and 479.84, respectively, would be modified by removing subparagraph (c) from each regulation and simply removing the notification requirement. While it may seem to be a small step, this would be a positive development for every applicant who seeks to make or transfer an NFA firearm in the future.
Please note that this is a proposed regulation change, so for the time being, it’s business as usual, and the CLEO notification requirement remains in place. That word matters. Proposed means the old system is still alive until the rule is finalized.
Comment Deadline For The ATF CLEO Notification Rule
The comment period for this change ends on July 6, 2026. Those who are so inclined may submit comments here: Federal Register :: Removing CLEO Notification Under the National Firearms Act
This regulation change is only one of many, which you can read on the “ATF’s New Era of Reform” page: ATF’s New Era of Reform | ATF
The Bottom Line For NFA Applicants
This may not sound like a revolutionary change on paper, but anyone who has wrestled with NFA forms knows how much small friction matters. Killing the CLEO notification requirement would not erase NFA registration, and it would not remove the background check process, but it would eliminate one more awkward, useless, and widely disliked step from the path to lawful NFA ownership.
For collectors, suppressor buyers, SBR makers, SBS owners, and anyone else dealing with the NFA system, that is nothing. Sometimes reform comes as a lightning bolt. Sometimes it comes as one stupid form copy, finally getting shown the door.
Related Reads From GunsAmerica Digest
- GOA Breaks Down ATF’s 34 New Rules
- Free SBRs Are Coming! A Horrible Idea
- Silencer Form 4s Exploded After the Tax Hit $0
Ernest Lintner is a lifelong firearms enthusiast who enlisted in the Air Force after high school. That led to an assignment to RAF Greenham Common, England which gifted him with opportunities to visit the Soviet Union in its waning days, complete the Vierdaagse at Nijmegen, Netherlands, and “work” full time in an armory. After returning home, he served as a city and state law enforcement officer before embarking on a career with ATF where he was assigned to three Industry Operations field offices, NFA, and NICS. Retiring in 2025, he founded Firearm Compliance Solutions LLC, a firearms industry consulting company. Other hobbies include military history, bunkers, masonry forts, museums, WWII memoirs, and lighthouses.
I’ve been the NFA game for a long time. When I did my first transfer decades ago I literally had to mail the original Form 4 to the sheriff and hope for the best. Luckily, the sheriff signed the acknowledgement and I was on my way. I am familiar with an instance where another sheriff would simply ignore filings and it took a collective group of doctors, lawyers, Indian chiefs, and other muckety mucks to bring a class action seeking relief under a Writ of Mandamus. Long story short they prevailed.
Obviously a lot changed since then. When the government revised the processing of NFA gun trusts when that became all the rage, if you read the reasoning behind it, the government acknowledged the difficulties of CLEO notification and the general misunderstanding of a CLEO “approving” the NFA transfer versus mere acknowledgement, which itself is something of an anachronism in the 21st century. Thus they changed it to the certification of notification, laying the burden of disqualification upon the CLEO to notify ATF and make the case.
I just looked at the e-form 4 (version December 2025) and this is still the case but it is really not much of a burden to mail a letter. So I don’t think this notification thing is really worth getting wrapped around the axle on. Don’t get me wrong, I think we need to continue the momentum with NFA reform or really just dispensing with it altogether, but it certainly is not an impediment at this point. Frankly, trusts are probably more of an impediment than CLEO notification, and are probably not necessary but I see why they were a pathway in the past.
I live in one of those city’s where the CLEO goes out of his way to interfere with our 2nd amendment rights in any way he can. When it came time to renew my CCL, he deliberately delayed the process for 15 months even though the paperwork was submitted the first day of the 90 day window, prior to expiration.
He got sued for interfering with the process by our local gun-right organization, lost, continued interfering, got sued again, but still uses delay tactics in any manner he can get away with. He’s a black BLM-supporting democrat and does everything in his power to turn the other cheek when it comes to crime within the ‘hood-rat’ community and gives the BLM’s a free hand in our city. And since gentrification has turned our fair city from a quaint polite Southern city into another Chicago, the ‘red’ community continues voting for this racist piece of garbage. Local politics shouldn’t have anything to do with this – but it does.
CLEO interaction is sill going to remain with the non-over the counter 4473 process if you’re obtaining a NFA item or firearm delivered through the mail.
All my NFA purchases since 2016 have not been slowed by the CLEO notification requirement but I agree it seemed a pointless step as part of an overall process that I would prefer didn’t exist.
My sheriff has always shredded this paperwork without even looking at it. He says that, except for criminals, it’s none of his business to know who has guns, what kind, or how many.