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Posted: 5/5/2026 7:04:04 PM EDT
[Last Edit: DD1801][Edited]
I have two individually owned suppressors that I purchased 20 years ago (on paper form, not electronic), that I intend to transfer into my newly created trust. I have moved residence since I purchased those suppressors, but I am still within the same state. Do I need to actually do one of these 5320.20 forms? I have previously read that I do not, since my move was within the same state. And if so, is there any kind of a timeline requirement?  The confusions rests here: "If you have moved to another state since receiving an approved ATF Form 1 or 4, please submit an ATF Form 5320.20 Application to Transport Interstate or Temporarily Export Certain NFA Firearms prior to submitting another application. This will allow NFA Division to timely process your application and ensure compliance with GCA interstate transfer restrictions." If I do need to do one of these 5320.20 forms, can I submit it electronically? (Keeping in mind my two suppressors are on paper forms) And if so, do I need to wait for any kind of approval before transferring these suppressors into my trust? I also plan on submitting a few SBRs for approval, also into the trust. Does the 5320.20 for my suppressors have any bearing on the forms for the SBRs? (ie do I need to wait for any kind of approval of the 5320.20 for my suppressors, before I submit SBR applications?) Edit - fixed title to “intra” Edit - Update: I mailed a generic business letter on/about May 8th with my new address. Received correspondence today (May 30th). The correspondence received was a pink "cover sheet" which all it said was "LIMITED OFFICIAL USE ONLY//FEDERAL TAXPAYER INFORMATION (When forms are filled out)", along with some sort of tracking number, a bar code, and my name/address. This pink "cover sheet" was stapled to a copy of my business letter, with my new address highlighted. |
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Originally Posted By DD1801: I have two individually owned suppressors that I purchased 20 years ago (on paper form, not electronic), that I intend to transfer into my newly created trust. I have moved residence since I purchased those suppressors, but I am still within the same state. Do I need to actually do one of these 5320.20 forms? I have previously read that I do not, since my move was within the same state. And if so, is there any kind of a timeline requirement? The confusions rests here: "If you have moved to another state since receiving an approved ATF Form 1 or 4, please submit an ATF Form 5320.20 Application to Transport Interstate or Temporarily Export Certain NFA Firearms prior to submitting another application. This will allow NFA Division to timely process your application and ensure compliance with GCA interstate transfer restrictions." If I do need to do one of these 5320.20 forms, can I submit it electronically? (Keeping in mind my two suppressors are on paper forms) And if so, do I need to wait for any kind of approval before transferring these suppressors into my trust? I also plan on submitting a few SBRs for approval, also into the trust. Does the 5320.20 for my suppressors have any bearing on the forms for the SBRs? (ie do I need to wait for any kind of approval of the 5320.20 for my suppressors, before I submit SBR applications?) Edit - fixed title to “intra” The Form 5320 is only needed to take some NFA items across state lines, and as others have said, for whatever reason, not needed for cans or AOW's. Same state moves do not need that form for any NFA item. The Form 1 and 4 say right on the back of it something like "Applicate shall notify ATF of any permanent move from the address in box 2a", which is your address when you bought or made it. You can just write up a business style letter and mail it into them, listing the items and their serial numbers, and new/old address. I did, and got a copy back of it marked "Received". Other people have said they've done that, and gotten a letter back asking for a Form 5320, even for cans, which makes zero sense, but it's what a poorly run organization does - not have set standards that are internally enforced. The main issue with not telling them of your move is that if/when you go to sell anything or put it into a trust/take it out, the new form's address doesn't match your old one, and they want that fixed first, before they approve another form. |
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Originally Posted By 1stID: The Form 5320 is only needed to take some NFA items across state lines, and as others have said, for whatever reason, not needed for cans or AOW's. Same state moves do not need that form for any NFA item. The Form 1 and 4 say right on the back of it something like "Applicate shall notify ATF of any permanent move from the address in box 2a", which is your address when you bought or made it. You can just write up a business style letter and mail it into them, listing the items and their serial numbers, and new/old address. I did, and got a copy back of it marked "Received". Other people have said they've done that, and gotten a letter back asking for a Form 5320, even for cans, which makes zero sense, but it's what a poorly run organization does - not have set standards that are internally enforced. The main issue with not telling them of your move is that if/when you go to sell anything or put it into a trust/take it out, the new form's address doesn't match your old one, and they want that fixed first, before they approve another form. Good to know. Now, I know I shouldn’t talk common sense here, but you would think that the transfer form with new updated address should count as notifying them of the address change. Not to mention my name would be on the RPQ so they would know it never left my possession. Maybe I’ll do like you say and just send a generic type business letter. Think I should send it certified with a read receipt? Thank you. |
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I think they just like to do one thing at a time - change of address - records updated. Moved to trust - records update. Plus you're supposed to notify them when you move, and it's not likely you move things into a trust at exactly the same time, so they may pushback on handling two things at once, when you should have done the move letter beforehand. Business letter is the way to go - no need for extra cost, just put a stamp on it. The risk isn't the PO loses it, it's that either ATF does, as as above, some employee thinks the 5320 is the form needed for an address change, since that's what's often used, but while sufficient, is not necessary. But most likely you'll be fine. Get the address issue taken care of, then move things into a trust. If you don't get anything back after maybe a month, give them a call to see if they've gotten the letter and just haven't responded back. |
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Originally Posted By DD1801: What about typing the business letter, ink signing it, scanning it, and emailing it to their email address on the form instructions? https://www.ar15.com/media/mediaFiles/69882/IMG_4660-3758532.png |
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One thing to keep in mind is that while you are not legally required to notify the BATFE about an intra-State move for any NFA firearm nor legally required to notify the BATFE for inter-State moves for Suppressors or AOW, or use their 5320.20 Form to notify them about a move.....you run the risk of running into issues down the road if/when you need to re-engage the BATFE for some other type of application approval you need from them and the address on the application doesn't match the address in the registry. If you don't notify them about a move and/or don't use their 5320.20 form and follow their process and just tell them to FOAD......don't be surprise if/when you need to them to actually approve a future Form 4 for a sale of that NFA firearm and/or you need an actual approved 5320.20 to take your SBR to another State to run into either application denials or delays on that future application request (until you correct your address), or in the case of a paper form applications being returned to you to via US mail that the approved paperwork is mailed to the old registrant address on file. I have personally historically seen all of this happen where future applications are denied/delayed and/or approved paperwork is mailed off to oblivion when folks didn't keep their address up to date with the BATFE. Now will you run into future application issues 100% of the time if you don't update your address the answer is no. I am sure there will be folks responding here about how they moved, never notified the BATFE and it all worked out for them on a future application, which is great for them. If there is one thing the BATFE is consistent about its that they are not consistent about the application of their "rules". Whether its fingerprint card counts, Trust paperwork exemptions, providing pictures/not providing pictures, picture age (can be be B&W or Color), what is legally the model name and does it have dash or not, etc. etc. Again this everybody's personal call on how they want to handle this. For me personally its easier to keep everything up to date with the BATFE so that when I am submitting 5320.20 to go on vacation or Form 4s to sell a gun that I don't run into application problems at that time. |
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Originally Posted By DD1801: Good to know. Now, I know I shouldn’t talk common sense here, but you would think that the transfer form with new updated address should count as notifying them of the address change. Not to mention my name would be on the RPQ so they would know it never left my possession. Maybe I’ll do like you say and just send a generic type business letter. Think I should send it certified with a read receipt? Thank you. As already said, it isn’t necessary. You don’t send in a 5320.20 for cans or intrastate moves. I moved last summer, I have 3 cans and a Form 1 SBR approved since my move halfway across the country. I sent in 5320.20’s for 12 items out of the 36 I owned at the time of my move. I shot a couple of emails back and forth for one SBR because I had a typo on the form. There was no mention of the other 24 items (23 cans and 1 AOW) in any of the correspondence because notification of either type of move isn’t necessary. Read page 2 Section a of the 5320.20. I have a Form 1 SBR in right now and 3 more cans going in shortly. I’m 100% sure there won’t be any issues. |
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From looking at the Form 5320.20, it really seems like its not the correct form for updating your permanent address. The Form is titled: "Application to Transport Interstate or to Temporarily Export Certain National FirearmsAct (NFA) Firearms" (not doing either of those actions) The instructions state: "A written request and prior authorization from ATF to transport interstate or in foreign commerce any destructive device, machinegun, short-barreled rifle, or short-barreled shotgun is required under the provisions of Title 18, United States Code (U.S.C) Section § 922 (a)(4) and Title 27, Code of Federal Regulations (CFR) § 478.28. A letter of request, in duplicate, containing all information required on this form, may be submitted in lieu of the form." (doesn't address suppressors. Also states that a letter may be submitted in lieu of the form.) And you can keep reading the instructions/guidance/authority/notice on the back of the form. Sorry for the ramblings, I haven't done anything NFA in 20 years. Glad I don't do this for a living, you'd go crazy at the inconsistencies/vagueness with the atf. |
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Originally Posted By DD1801: From looking at the Form 5320.20, it really seems like its not the correct form for updating your permanent address. The Form is titled: "Application to Transport Interstate or to Temporarily Export Certain National FirearmsAct (NFA) Firearms" (not doing either of those actions) The instructions state: "A written request and prior authorization from ATF to transport interstate or in foreign commerce any destructive device, machinegun, short-barreled rifle, or short-barreled shotgun is required under the provisions of Title 18, United States Code (U.S.C) Section § 922 (a)(4) and Title 27, Code of Federal Regulations (CFR) § 478.28. A letter of request, in duplicate, containing all information required on this form, may be submitted in lieu of the form." (doesn't address suppressors. Also states that a letter may be submitted in lieu of the form.) And you can keep reading the instructions/guidance/authority/notice on the back of the form. Sorry for the ramblings, I haven't done anything NFA in 20 years. Glad I don't do this for a living, you'd go crazy at the inconsistencies/vagueness with the atf. It isn’t the correct form. There is no correct form. There is no requirement for suppressors or AOWs for any type of move/change of address or travel. It is also not the correct form because there is no requirement for intrastate moves for any NFA item. Read the top corner of the form.  You’re trying to find a form and a requirement that do not exist. |
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Originally Posted By DD1801: From looking at the Form 5320.20, it really seems like its not the correct form for updating your permanent address. The Form is titled: "Application to Transport Interstate or to Temporarily Export Certain National FirearmsAct (NFA) Firearms" (not doing either of those actions) The instructions state: "A written request and prior authorization from ATF to transport interstate or in foreign commerce any destructive device, machinegun, short-barreled rifle, or short-barreled shotgun is required under the provisions of Title 18, United States Code (U.S.C) Section 922 (a)(4) and Title 27, Code of Federal Regulations (CFR) 478.28. A letter of request, in duplicate, containing all information required on this form, may be submitted in lieu of the form." (doesn't address suppressors. Also states that a letter may be submitted in lieu of the form.) And you can keep reading the instructions/guidance/authority/notice on the back of the form. Sorry for the ramblings, I haven't done anything NFA in 20 years. Glad I don't do this for a living, you'd go crazy at the inconsistencies/vagueness with the atf. But I can tell you from a lot of experience doing NFA stuff for myself and seeing others in the past 15 years, that for permanent moves they want you to use that form, even if you do an intrastate move and it's not legally required for the suppressors, they still request you use that form to tell them so they can keep the registry up to date. People who have tried sending a written letter instead of that form have had them returned with instruction to fill out a form 5320.20 instead. 
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Over the past couple decades I have easily submitted multiple hundreds of 5320.20s to the BATFE NFA Branch to notify them of both permanent intra-State address changes as well as temporary inter-State move requests. I can with absolute 100% certainty tell you that the 5320.20 is the correct application form for both of these situations. |
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Originally Posted By D_Man: You read that all correct. But I can tell you from a lot of experience doing NFA stuff for myself and seeing others in the past 15 years, that for permanent moves they want you to use that form, even if you do an intrastate move and it's not legally required for the suppressors, they still request you use that form to tell them so they can keep the registry up to date. People who have tried sending a written letter instead of that form have had them returned with instruction to fill out a form 5320.20 instead. Some have, some haven't. I wrote a business letter, and got a copy of it back, marked Received. Let's look at the actual facts: 1. The 5320 form, as it says right on it, is a "Application to Transport Interstate or to Temporarily Export Certain National Firearms Act (NFA) Firearms." It's the form created to allow compliance with Federal rulings that some NFA items need permission from the ATF to cross state lines. It is sufficient to use for a permanent move, across state lines, of MG, DD, SBS, SBR. 2. For an intrastate move, there's no requirement to obtain permission, so ATF does not have a form for it. The above 5320 is for interstate moves, not intrastate. Could you use it to update your address? Yes. Could some mixed up or lazy employee claim you need it for an intrastate move? Yes. Would that be correct? No. 3. There is also no requirement to obtain permission for silencer or AOW movement across state lines, so the 5320 is again, the incorrect form to use to inform ATF of your move. Why are you asking permission to do something, when no permission is required? 4. It says right on the back of a Form 4 "Change of Address. Unless currently licensed under the Gun Control Act, the registrant shall notify the NFA Division in writing of any change to the address in item 3a." Shall in legal terms means "you have to, no exceptions." Now is this requirement something ATF made up, and isn't matched up with Federal statues, or Final Rules? Don't know! Or care. It says right on the Form you have to tell them you new address, so it's pretty undefendable if you don't. It also makes no mention of a Form 5320, just to "notify'. A business letter is all the notification needed, for intrastate moves, or interstate moves of silencers or AOW. Now will your business letter get sent back and they claim you need a 5320? Just look at the topics here of various errors ATF has made with Forms to give you an idea of how consistent, and correct to their own rules, they are. But my thought is to use what's correct first, and take it from there if it's sent back. |
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Originally Posted By 1stID: Some have, some haven't. I wrote a business letter, and got a copy of it back, marked Received. Let's look at the actual facts: 1. The 5320 form, as it says right on it, is a "Application to Transport Interstate or to Temporarily Export Certain National Firearms Act (NFA) Firearms." It's the form created to allow compliance with Federal rulings that some NFA items need permission from the ATF to cross state lines. It is sufficient to use for a permanent move, across state lines, of MG, DD, SBS, SBR. 2. For an intrastate move, there's no requirement to obtain permission, so ATF does not have a form for it. The above 5320 is for interstate moves, not intrastate. Could you use it to update your address? Yes. Could some mixed up or lazy employee claim you need it for an intrastate move? Yes. Would that be correct? No. 3. There is also no requirement to obtain permission for silencer or AOW movement across state lines, so the 5320 is again, the incorrect form to use to inform ATF of your move. Why are you asking permission to do something, when no permission is required? 4. It says right on the back of a Form 4 "Change of Address. Unless currently licensed under the Gun Control Act, the registrant shall notify the NFA Division in writing of any change to the address in item 3a." Shall in legal terms means "you have to, no exceptions." Now is this requirement something ATF made up, and isn't matched up with Federal statues, or Final Rules? Don't know! Or care. It says right on the Form you have to tell them you new address, so it's pretty undefendable if you don't. It also makes no mention of a Form 5320, just to "notify'. A business letter is all the notification needed, for intrastate moves, or interstate moves of silencers or AOW. Now will your business letter get sent back and they claim you need a 5320? Just look at the topics here of various errors ATF has made with Forms to give you an idea of how consistent, and correct to their own rules, they are. But my thought is to use what's correct first, and take it from there if it's sent back. I still don’t understand why anyone would send anything in for an intrastate move. |
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Originally Posted By cardboardkiller: I still don’t understand why anyone would send anything in for an intrastate move. Because there are decent odds it will just come back to bite you, your heirs, or a future buyer in the ass and cause problems when you don't have the luxury of time on your side. You have plans to bring your MG/SBR/SBS/DD with you on vacation out of State and send in a 5320.20 for a temporary inter-State transfer request from your new address to the temporary out of State destination and the 5320.20 for your trip comes back "denied" with the reason being you need to first submit a 5320.20 to correct your permanent address and then once that is approved to resubmit the inter-State 5320.20 transfer request from the new address. Do to the timing you don't have time to resubmit and it messes up your plans to bring the gun with you for the trip. I have seen that exact scenario happen plenty of times. I have also personally had multiple approved Form 4s of guns I have bought mailed to the old address of the seller because they didn't bother to update their address with the BATFE. Some approved Form 4s I have chased down successfully at the old address and others I have not. For the ones that were lost it then becomes a "wait 45 days before you can submit for a certified copy" and then wait another month for the certified copy to show up. Gee thanks for causing me a two+ month delay to pick up my gun from you because you couldn't spend 5 minutes to fill out a 5320.20 when you moved 5 years ago. Its a pointless protest to not to update your address when you move , even if its in State. Its not like the the BATFE can't find you anymore should they choose to. I also can't figure why anybody wouldn't just use the form the BATFE specifically publishes for this purpose vs. trying to get them to take something else that may just come back denied and then you just have to start all over and resubmit using the very application form they publish specifically for that purpose that you refused to use in the first place. Its akin to my idiot brother in law who refuses to update his State ID card when he moves (because F the man) and then it causes him endless grief because the address on his ID doesn't match where he lives anymore. |
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Originally Posted By jbntex: Because there are decent odds it will just come back to bite you, your heirs, or a future buyer in the ass and cause problems when you don't have the luxury of time on your side. You have plans to bring your MG/SBR/SBS/DD with you on vacation out of State and send in a 5320.20 for a temporary inter-State transfer request from your new address to the temporary out of State destination and the 5320.20 for your trip comes back "denied" with the reason being you need to first submit a 5320.20 to correct your permanent address and then once that is approved to resubmit the inter-State 5320.20 transfer request from the new address. Do to the timing you don't have time to resubmit and it messes up your plans to bring the gun with you for the trip. I have seen that exact scenario happen plenty of times. I have also personally had multiple approved Form 4s of guns I have bought mailed to the old address of the seller because they didn't bother to update their address with the BATFE. Some approved Form 4s I have chased down successfully at the old address and others I have not. For the ones that were lost it then becomes a "wait 45 days before you can submit for a certified copy" and then wait another month for the certified copy to show up. Gee thanks for causing me a two+ month delay to pick up my gun from you because you couldn't spend 5 minutes to fill out a 5320.20 when you moved 5 years ago. Its a pointless protest to not to update your address when you move , even if its in State. Its not like the the BATFE can't find you anymore should they choose to. I also can't figure why anybody wouldn't just use the form the BATFE specifically publishes for this purpose vs. trying to get them to take something else that may just come back denied and then you just have to start all over and resubmit using the very application form they publish specifically for that purpose that you refused to use in the first place. Its akin to my idiot brother in law who refuses to update his State ID card when he moves (because F the man) and then it causes him endless grief because the address on his ID doesn't match where he lives anymore. 1. I (and the topic of this thread) was originally referring to silencers and AOW’s. So your rant is moot. 2. What is the correct form to update your address for an intrastate move? There is none. There is also no legal requirement. There’s no practical reason to do it if you have a trust with heirs named on it. I’ve been in the NFA game 20 years this year and haven’t had one single issue with an approval related to an address. I’ve had exactly 2 forms sent back for corrections and both were Form 4’s where the dealer made a mistake. |
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Quote: I still don’t understand why anyone would send anything in for an intrastate move. As I wrote: It says right on the back of a Form 4 "Change of Address. Unless currently licensed under the Gun Control Act, the registrant shall notify the NFA Division in writing of any change to the address in item 3a." Shall in legal terms means "you have to, no exceptions." Now is this requirement something ATF made up, and isn't matched up with Federal statues, or Final Rules? Don't know! Or care. It says right on the Form you have to tell them you new address, so it's pretty undefendable if you don't. I have no idea where people get this "you don't have to update your address with them if you move in the same state", when right on the form you yourself fill out and sign, it says you shall do so. Is there a form for updating your address? No, since the information is just one way - you to them. There's a set form for an Interstate transport because they have to send the form back to you, and they want all the data needed to approve the form, and return it to you so that it's valid. This topic always brings out two erroneous schools of though - the "don't need to tell them nothing about an instate move or silencers/AOW, there's no form for it" crowd, and the "Use 5320 for all things, even things it's not created to do, and for things where there truly is no legal requirement, such as permission to cross state lines with a silencer or AOW" crowd. Myself I'm in the "do what the Form 1 and 4 says you shall do" and "don't use a form for something not needed" crowd. Seems simpler and more defendable that way. |
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Originally Posted By jbntex: Because there are decent odds it will just come back to bite you, your heirs, or a future buyer in the ass and cause problems when you don't have the luxury of time on your side. You have plans to bring your MG/SBR/SBS/DD with you on vacation out of State and send in a 5320.20 for a temporary inter-State transfer request from your new address to the temporary out of State destination and the 5320.20 for your trip comes back "denied" with the reason being you need to first submit a 5320.20 to correct your permanent address and then once that is approved to resubmit the inter-State 5320.20 transfer request from the new address. Do to the timing you don't have time to resubmit and it messes up your plans to bring the gun with you for the trip. I have seen that exact scenario happen plenty of times. I have also personally had multiple approved Form 4s of guns I have bought mailed to the old address of the seller because they didn't bother to update their address with the BATFE. Some approved Form 4s I have chased down successfully at the old address and others I have not. For the ones that were lost it then becomes a "wait 45 days before you can submit for a certified copy" and then wait another month for the certified copy to show up. Gee thanks for causing me a two+ month delay to pick up my gun from you because you couldn't spend 5 minutes to fill out a 5320.20 when you moved 5 years ago. Its a pointless protest to not to update your address when you move , even if its in State. Its not like the the BATFE can't find you anymore should they choose to. I also can't figure why anybody wouldn't just use the form the BATFE specifically publishes for this purpose vs. trying to get them to take something else that may just come back denied and then you just have to start all over and resubmit using the very application form they publish specifically for that purpose that you refused to use in the first place. Its akin to my idiot brother in law who refuses to update his State ID card when he moves (because F the man) and then it causes him endless grief because the address on his ID doesn't match where he lives anymore. The 5320 isn't specifically published for intrastate, or silencer/AOW movement across state lines, hence the title "Application to Transport Interstate or to Temporarily Export Certain National Firearms Act (NFA) Firearms." If it was specifically published for that purpose, it would have the name of something like "Notification Form for Permanent Address Change of All NFA Items." The ATF forms are permission slips. You fill them out, they approve them, and return them to you as proof you've followed the law. There's no permission needed for an intrastate move, or moving silencers/AOW's across state lines, so ATF correctly doesn't have form for that, just instructs you (again, right on the back of the Form 1 or 4) to notify them of you new address. This isn't some complicated math equation. The "shall notify", "interstate", and "certain NFA firearms" phrases tell you everything you need to know. If people just ignore the words on the form, cuz this or that has happened to them or their buddy or they heard about it at a gun shop, then that's their choice. But it's terrible advice to give to someone starting out with NFA stuff: "Hey just ignore the words on the ATF forms, here's what ya really need to do!" |
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Originally Posted By cardboardkiller: 1. I (and the topic of this thread) was originally referring to silencers and AOW’s. So your rant is moot. 2. What is the correct form to update your address for an intrastate move? There is none. There is also no legal requirement. There’s no practical reason to do it if you have a trust with heirs named on it. I’ve been in the NFA game 20 years this year and haven’t had one single issue with an approval related to an address. I’ve had exactly 2 forms sent back for corrections and both were Form 4’s where the dealer made a mistake. Your reply was "I still don’t understand why anyone would send anything in for an intrastate move." There was nothing to suggest this was a suppressor or AOW only discussion at this point. (The OPs initial post had nothing to do with AOWs either.) I just provided personal first hand examples of what can happen if you decide not to update your address with the ATF. I have been doing this for decades as well and have submitted hundreds of NFA applications over the years. I have local friends who have my exact same experience submitting hundreds of applications including 5320.20s over the years. I can tell you even when everything should be perfect and your address is updated on the application, collectively we still run into recurring problems with the ATF. Forms getting denied, Forms being sent back for correction, Forms never received on their end, approved Forms that are never returned or lost, etc. If things are not correct on the initial application (like the address) the odds of problems go up significantly. I have personally lost count of the number of issues I have had over the years and I try and keep all of my records up to date and correct. When I am going to big out of State machinegun shoot where I am submitting a couple dozen 5320.20, at this point I know to expect problems and actually proactively plan for those anticipated 5320.20 issues. I honestly don't care what anybody else does or doesn't do. I am not looking to get into an argument with somebody on the internet. If you don't want to update your address for an intra-State move or its a suppressor or AOW for an inter-State move and its "legally not required" that is your right to do so. I am just relaying my experience that if you decide not to.... don't be surprised if you run into issues with future legally required application submissions if the address doesn't match. |
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Originally Posted By 1stID: The 5320 isn't specifically published for intrastate, or silencer/AOW movement across state lines, hence the title "Application to Transport Interstate or to Temporarily Export Certain National Firearms Act (NFA) Firearms." If it was specifically published for that purpose, it would have the name of something like "Notification Form for Permanent Address Change of All NFA Items." The ATF forms are permission slips. You fill them out, they approve them, and return them to you as proof you've followed the law. There's no permission needed for an intrastate move, or moving silencers/AOW's across state lines, so ATF correctly doesn't have form for that, just instructs you (again, right on the back of the Form 1 or 4) to notify them of you new address. This isn't some complicated math equation. The "shall notify", "interstate", and "certain NFA firearms" phrases tell you everything you need to know. If people just ignore the words on the form, cuz this or that has happened to them or their buddy or they heard about it at a gun shop, then that's their choice. But it's terrible advice to give to someone starting out with NFA stuff: "Hey just ignore the words on the ATF forms, here's what ya really need to do!" Originally Posted By 1stID: Originally Posted By jbntex: Because there are decent odds it will just come back to bite you, your heirs, or a future buyer in the ass and cause problems when you don't have the luxury of time on your side. You have plans to bring your MG/SBR/SBS/DD with you on vacation out of State and send in a 5320.20 for a temporary inter-State transfer request from your new address to the temporary out of State destination and the 5320.20 for your trip comes back "denied" with the reason being you need to first submit a 5320.20 to correct your permanent address and then once that is approved to resubmit the inter-State 5320.20 transfer request from the new address. Do to the timing you don't have time to resubmit and it messes up your plans to bring the gun with you for the trip. I have seen that exact scenario happen plenty of times. I have also personally had multiple approved Form 4s of guns I have bought mailed to the old address of the seller because they didn't bother to update their address with the BATFE. Some approved Form 4s I have chased down successfully at the old address and others I have not. For the ones that were lost it then becomes a "wait 45 days before you can submit for a certified copy" and then wait another month for the certified copy to show up. Gee thanks for causing me a two+ month delay to pick up my gun from you because you couldn't spend 5 minutes to fill out a 5320.20 when you moved 5 years ago. Its a pointless protest to not to update your address when you move , even if its in State. Its not like the the BATFE can't find you anymore should they choose to. I also can't figure why anybody wouldn't just use the form the BATFE specifically publishes for this purpose vs. trying to get them to take something else that may just come back denied and then you just have to start all over and resubmit using the very application form they publish specifically for that purpose that you refused to use in the first place. Its akin to my idiot brother in law who refuses to update his State ID card when he moves (because F the man) and then it causes him endless grief because the address on his ID doesn't match where he lives anymore. The 5320 isn't specifically published for intrastate, or silencer/AOW movement across state lines, hence the title "Application to Transport Interstate or to Temporarily Export Certain National Firearms Act (NFA) Firearms." If it was specifically published for that purpose, it would have the name of something like "Notification Form for Permanent Address Change of All NFA Items." The ATF forms are permission slips. You fill them out, they approve them, and return them to you as proof you've followed the law. There's no permission needed for an intrastate move, or moving silencers/AOW's across state lines, so ATF correctly doesn't have form for that, just instructs you (again, right on the back of the Form 1 or 4) to notify them of you new address. This isn't some complicated math equation. The "shall notify", "interstate", and "certain NFA firearms" phrases tell you everything you need to know. If people just ignore the words on the form, cuz this or that has happened to them or their buddy or they heard about it at a gun shop, then that's their choice. But it's terrible advice to give to someone starting out with NFA stuff: "Hey just ignore the words on the ATF forms, here's what ya really need to do!" Contact the ATF and ask them which application Form you should use if "you choose" to notify them of a permanent intra-State move (per their non-legally binding request) and they will tell you to use the 5320.20. If you want get get into an esoteric argument with a faceless government bureaucrat (for which you have effectively zero recourse), that the 5320.20 application form they will specifically tell you to use to notify them of a permanent intra-State move doesn't exactly match the instructions or the title of that form that is your choice. If you want to try an alternate notification method that they don't recommend, again its your choice. If your alternate notification method runs into issues you have effectively zero protest or recourse with them other than to resubmit using the 5320.20. Sure you can ignore their request to use a 5320.20 (as its not legally required in the first place) but then when you submit a future application that you may legally need their approval for you may run into problems at that time. |
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Originally Posted By jbntex: Your reply was "I still don’t understand why anyone would send anything in for an intrastate move." There was nothing to suggest this was a suppressor or AOW only discussion at this point. (The OPs initial post had nothing to do with AOWs either.) I just provided personal first hand examples of what can happen if you decide not to update your address with the ATF. I have been doing this for decades as well and have submitted hundreds of NFA applications over the years. I have local friends who have my exact same experience submitting hundreds of applications including 5320.20s over the years. I can tell you even when everything should be perfect and your address is updated on the application, collectively we still run into recurring problems with the ATF. Forms getting denied, Forms being sent back for correction, Forms never received on their end, approved Forms that are never returned or lost, etc. If things are not correct on the initial application (like the address) the odds of problems go up significantly. I have personally lost count of the number of issues I have had over the years and I try and keep all of my records up to date and correct. When I am going to big out of State machinegun shoot where I am submitting a couple dozen 5320.20, at this point I know to expect problems and actually proactively plan for those anticipated 5320.20 issues. I honestly don't care what anybody else does or doesn't do. I am not looking to get into an argument with somebody on the internet. If you don't want to update your address for an intra-State move or its a suppressor or AOW for an inter-State move and its "legally not required" that is your right to do so. I am just relaying my experience that if you decide not to.... don't be surprised if you run into issues with future legally required application submissions if the address doesn't match. I didn’t submit 5320.20’s for 2 dozen items when I moved states and I keep receiving Form 1 and Form 4 approvals. My Sahara 300 that I bought after I moved beat my 5320.20’s hard copies to the house. Hopefully, the revision of all this goes through and they clear it all up where there’s no need for any of this except for the 365+ day and permanent interstate moves. |
| Update: I mailed a generic business letter on/about May 8th with my new address. Received correspondence today (May 30th). The correspondence received was a pink "cover sheet" which all it said was "LIMITED OFFICIAL USE ONLY//FEDERAL TAXPAYER INFORMATION (When forms are filled out)", along with some sort of tracking number, a bar code, and my name/address. This pink "cover sheet" was stapled to a copy of my business letter, with my new address highlighted. |
The Emperor is naked.
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Originally Posted By cardboardkiller: I still don’t understand why anyone would send anything in for an intrastate move. I’m with you in that, if it’s not required, why bother. Having said that, ATF now takes the passive aggressive approach. If you later file a 5320.20 to transport out of state, it will be returned to the address they have on file. Even if you list some other address in the “return to” field of the form. |
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Originally Posted By GarrettJ: I'm with you in that, if it's not required, why bother. Having said that, ATF now takes the passive aggressive approach. If you later file a 5320.20 to transport out of state, it will be returned to the address they have on file. Even if you list some other address in the "return to" field of the form. |
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Originally Posted By jbntex: Contact the ATF and ask them which application Form you should use if "you choose" to notify them of a permanent intra-State move (per their non-legally binding request) and they will tell you to use the 5320.20. If you want get get into an esoteric argument with a faceless government bureaucrat (for which you have effectively zero recourse), that the 5320.20 application form they will specifically tell you to use to notify them of a permanent intra-State move doesn't exactly match the instructions or the title of that form that is your choice. If you want to try an alternate notification method that they don't recommend, again its your choice. If your alternate notification method runs into issues you have effectively zero protest or recourse with them other than to resubmit using the 5320.20. Sure you can ignore their request to use a 5320.20 (as its not legally required in the first place) but then when you submit a future application that you may legally need their approval for you may run into problems at that time. Why would I contact ATF about what to do, when the very form I filled out to make or transfer the NFA item says right on it what to do? From the Form 1 or 4: Change of Address. Unless currently licensed under the Gun Control Act, the registrant shall notify the NFA Division in writing of any change to the address in item 3a." There's no reason to overthink this, or call and beg to be told what form to use. The answer is ... you don't need one. You just, as above, "notify the NFA Division in writing". That means you write them a letter, preferably in ink but I guess crayon would work too. There's no need to fill out a form, especially some form that only has spaces for 3 items on it, so if like any respectable NFA owner, you have about a dozen items, you'd need 4 forms. |
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Originally Posted By DD1801: Update: I mailed a generic business letter on/about May 8th with my new address. Received correspondence today (May 30th). The correspondence received was a pink "cover sheet" which all it said was "LIMITED OFFICIAL USE ONLY//FEDERAL TAXPAYER INFORMATION (When forms are filled out)", along with some sort of tracking number, a bar code, and my name/address. This pink "cover sheet" was stapled to a copy of my business letter, with my new address highlighted. Excellent, same response I've gotten. You threaded the needle between the "don't tell them nothing!!!", and the "use a 5320 for all things, even things it's not supposed to be used for" crowds. Top marks for, unlike many others in this topic, having actually read the back of your Forms, and followed the instructions. |
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Originally Posted By GarrettJ: I’m with you in that, if it’s not required, why bother. Having said that, ATF now takes the passive aggressive approach. If you later file a 5320.20 to transport out of state, it will be returned to the address they have on file. Even if you list some other address in the “return to” field of the form. Where are you coming up with this "not required"? Do you have a different Form 4 than I do, cuz mine says: "Change of Address. Unless currently licensed under the Gun Control Act, the registrant shall notify the NFA Division in writing of any change to the address in item 3a." If owning a NFA item required basic reading comprehension, then there would be about half the number of NFA owners. Now I supposed you can just ignore the words on the, checks notes, Federal form you yourself printed, signed, and mailed into the ATF, but I'm not sure how defendable that would be in court. |
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Bottom line: Yes, you need to notify the ATF if you own NFA items and move. Doesn’t matter if it’s a suppressor or AOW, or if it’s anything else. Yes, they want it on a 5320.20. No, the title of the form implies that it’s only for INTERstate moves or for temporary export. ATF should have fixed this, but they didn’t. It’s still the form they want used. If you move and don’t tell them, and you don’t do anything else with the NFA firearm, they’ll likely never know. But if you decide to travel interstate and the address on the registry doesn’t match the one on your 5320.20, there’ll be a denial and you’ll have to fix things. If you want to sell the NFA firearm, same story. And, God help us all, if the 2028 elections go badly, I could see a new administration with an activist ATF creating major problems for otherwise innocent owners who happened to commit some silly paperwork error like not updating their address. Just do it and be done, but no skin off my back if you choose this hill to die on. 
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“Don't post anything here or send anything you aren't willing to defend in court.”
-Notcalifornialegal
-Notcalifornialegal
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Originally Posted By prebans:If you move and don't tell them, and you don't do anything else with the NFA firearm, they'll likely never know. But if you decide to travel interstate and the address on the registry doesn't match the one on your 5320.20, there'll be a denial and you'll have to fix things. If you want to sell the NFA firearm, same story. And, God help us all, if the 2028 elections go badly, I could see a new administration with an activist ATF creating major problems for otherwise innocent owners who happened to commit some silly paperwork error like not updating their address. As to the new admin, I could see that. |
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Originally Posted By spyderboy03: I've never notified of an in state move and had several 5320.20's approved with a new address for the return address. As to the new admin, I could see that. …and I’ve seen them disapproved for that same thing. It really boils down to who is in charge at the time. |
“Don't post anything here or send anything you aren't willing to defend in court.”
-Notcalifornialegal
-Notcalifornialegal
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Originally Posted By prebans: Bottom line: Yes, you need to notify the ATF if you own NFA items and move. Doesn’t matter if it’s a suppressor or AOW, or if it’s anything else. Yes, they want it on a 5320.20. No, the title of the form implies that it’s only for INTERstate moves or for temporary export. ATF should have fixed this, but they didn’t. It’s still the form they want used. If you move and don’t tell them, and you don’t do anything else with the NFA firearm, they’ll likely never know. But if you decide to travel interstate and the address on the registry doesn’t match the one on your 5320.20, there’ll be a denial and you’ll have to fix things. If you want to sell the NFA firearm, same story. And, God help us all, if the 2028 elections go badly, I could see a new administration with an activist ATF creating major problems for otherwise innocent owners who happened to commit some silly paperwork error like not updating their address. Just do it and be done, but no skin off my back if you choose this hill to die on. There's no formal requirement to use a 5320 for intrastate moves, or AOW/suppressor moves. The Forms just say to notify in writing. Now will some examiners incorrectly think/want a 5320 - yes, just like the dozens of other things that are often incorrectly asked for by the NFA division. But many have said, including the OP of this topic, a business letter generally works, and is the first thing that should be tried for intrastate and AOW/suppressor moves. |
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Originally Posted By spyderboy03: I don't doubt that at all That’s really the biggest thing I tell NFA n00bs. The ATF is best regarded as a schizophrenic with violent tendencies. You can ask a question about whatever, get five wildly different answers, and nobody is lying. They’re telling you God’s honest truth based on the answer they got from five (or more) different people across multiple regions and with different people in power. |
“Don't post anything here or send anything you aren't willing to defend in court.”
-Notcalifornialegal
-Notcalifornialegal
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