I thought transfers that already took place to existing trusts were grandfathered - I don't know this for a fact, the status of this seems to be in flux.
When people first started using Trusts to do NFA transfers to get around the CLEO sign-off, I told people to be very concerned about this. BATFE can change the rules to screw you. They could go much further than what they seem to be doing. They could come out and say "no CLEO sign-off, then you can't use your NFA item, only keep it as an investment". In another time, when we citizens still had some degree of freedom, no one thought this could ever happen. Well, it's happening, and it sucks!!!
When people first started using Trusts to do NFA transfers to get around the CLEO sign-off, I told people to be very concerned about this. BATFE can change the rules to screw you. They could go much further than what they seem to be doing. They could come out and say "no CLEO sign-off, then you can't use your NFA item, only keep it as an investment". In another time, when we citizens still had some degree of freedom, no one thought this could ever happen. Well, it's happening, and it sucks!!!