08/14/2026
Update on Suppressor Transfers
We’ve had quite a few questions regarding the recent Silencer Shop v. ATF ruling and whether Punisher Built will begin transferring suppressors on a standard Form 4473 without an ATF Form 4.
Our position has shifted somewhat since yesterday for one major reason:
Suppressors are still being transferred from distributors to dealers on ATF Form 3s.
That means those suppressors are still being registered to the receiving dealer in the NFRTR.
A central issue in this lawsuit was whether the federal government can continue requiring NFA registration under its taxing authority now that Congress has reduced the applicable NFA tax to $0. Given that, we’re disappointed that the current process still appears to rely on Form 3 registration when transferring suppressors into dealer inventory.
That creates an important unanswered question for us as an FFL/SOT:
If a suppressor is transferred and registered to Punisher Built on a Form 3, and we subsequently transfer that suppressor to a customer using only a Form 4473, what happens to that suppressor in the NFRTR?
Our A&D records would show that the suppressor was lawfully disposed to a customer, while the NFRTR could continue showing that same suppressor registered to Punisher Built.
That is an unresolved compliance issue we are not comfortable ignoring.
There is also still time for the federal government to appeal the decision. If the legal landscape changes after we have completed 4473-only transfers, we want to know exactly how ATF expects those previously transferred suppressors—and our NFA inventory records—to be handled.
Please don’t misunderstand our intention.
We support the ruling. We’re excited about where this may be headed, and we would love to see suppressor purchases handled like ordinary fi***rm transactions.
We simply want the compliance side to be clear before changing our transfer procedures. Protecting our customers and protecting our FFL/SOT have to come first.
Hopefully this issue is clarified quickly and we can move forward with our original intention of offering 4473-only Silencer Shop suppressor transfers.
Roy Rhodes
Owner
Punisher Built
