Important Suppressor Industry Update

At this time, Off Grid Suppressors and Off Grid Armory will continue processing customer suppressor transfers through the established ATF Form 4 process. We are not currently completing suppressor transfers using a Form 4473 alone.

We are closely monitoring the legal and regulatory developments surrounding this ruling. If additional guidance or changes provide a clear and compliant path for us to modify our transfer procedures, we will update our customers promptly.

No. Not at this time.

We recognize that there has been considerable discussion surrounding the ruling, and we have received many questions from customers about whether we can immediately begin completing suppressor transfers using only a Form 4473.

For us, there are important federal licensing, inventory, and recordkeeping requirements that must be addressed before we can make any change to our current transfer procedures.

As a Type 07 Federal Firearms Licensee and Class 3 Special Occupational Taxpayer, our NFA-regulated inventory is accounted for through the National Firearms Registration and Transfer Record (NFRTR).

We are responsible for maintaining accurate records and accounting for regulated items associated with our federal licenses. Until there is clear legal and regulatory guidance establishing how affected suppressors may be removed from the NFA system and transferred through an alternative process, we will continue using the existing Form 4 procedure.

Our priority is to serve our customers while maintaining full compliance with the requirements applicable to our federal licenses and business operations. We will not make a change to our transfer procedures until we are confident that we can do so lawfully and responsibly.

If a suppressor arrives at Off Grid Armory and remains subject to the NFA transfer system in our records, the customer transfer will continue to be processed through a Form 4.

For those transfers, the requirements associated with the Form 4 process will continue to apply unless and until applicable legal or regulatory guidance changes.

We have also received questions about the difference between Form 3 and Form 4 transfers.

Form 3
Generally used for tax-exempt transfers of NFA firearms between qualified Federal Firearms Licensees/Special Occupational Taxpayers.

Form 4
Generally used to transfer an NFA firearm from a dealer to an individual or other eligible transferee.

For our customers purchasing a suppressor, the Form 4 is generally the relevant transfer process.

There is ongoing litigation challenging aspects of federal regulation involving suppressors and certain other NFA-regulated items, particularly following the reduction of the federal making and transfer tax on suppressors to $0.

These legal challenges could result in additional changes to the regulatory landscape.

However, there is an important distinction between potential future changes to suppressor regulation and the procedures Offgrid is authorized and prepared to follow today.

Offgrid will not begin offering 4473-only suppressor transfers unless and until we are confident that our federal licensing requirements, inventory records, and transfer procedures provide a clear and compliant path for doing so.

Off Grid will continue monitoring developments involving:

• ATF and NFA Branch guidance
• ATF eForms
• The National Firearms Registration and Transfer Record (NFRTR)
• Additional court orders, appeals, and related litigation
• Guidance affecting Federal Firearms Licensees
• Applicable state requirements

If legal or regulatory developments allow Off Grid to complete suppressor transfers using a Form 4473 without the traditional Form 4 process, we will communicate that change to our customers as soon as we are prepared to implement it.

For official updates regarding Off Grids transfer procedures, please refer to our website and Facebook page.