08/13/2026
Can I buy a suppressor without a Form 4 now?
As of 8/13/26, most dealers like us are still waiting for ATF guidance since transferring one without a form 4 doesn't remove them from our federal inventory records.
There is a long paper trial & inventory record for dealers with NFA items (Suppressors, SBR, SBS, AOW, MG, etc.). If we start transferring them like regular fi****ms they don't get removed from our "federal" inventory..
We’re going to need some guidance or information stating they are deleting these items from our inventory (or completely from the registry). So we won't be held liable for transferring without the paperwork required under the official guidelines for FFLs. These are some major questions that need to be answered:
A. With this injunction, are suppressors being sent to us dealers as a normal bound book transfer or on a Form 3 into our NFA inventory?
B. Is there a process to have such items disposed of on a 4473 removed from our inventory?
C. What happens during an audit if we can't produce the serial numbers for NFA items shown in our inventory list because they were disposed of without a Form 4 to remove them from our inventory?
With the current NFA Guidelines, a dealer would lose their license & possibly be charged with federal felonies.
The historic 8/13/26 @ 12:01am 4473 suppressor transfers involved pretty exclusively the companies & individuals involved in the lawsuit & ruling, so they are supported by their team lawyers for legal counsel and representation.
"... but Silencer Shop said" is not a defense we choose to stand on without more clarification and guidance.
With Form 4 approval mostly under a week right now we don't see the point in risking it at this time. The appeal window for the DOJ is still open for another 53 days, so there is still some time for changes to occur.
We are closely monitoring the progress of this case and will adapt in full compliance as the guidelines for FFLs are updated by the ATF since they are the ones that issue and revoke our license.
Now a little possible foresight. Once this is all ironed out it will be a huge step in the right direction for suppressors. This is just the first step of the lawsuit challenge process; goal, to get them out of the NFA.
The next step will be to clear them of the GCA (gun control act), so you can just buy them like a pair of ear muffs.
How could that happen? Previously the DOJ had challenged that suppressors weren't fi****ms because they don't meet the regulatory definition and therefore should not be protected under the 2nd amendment. The Supreme Court disagreed and said that firearm components / accessories are essential components for fi****ms and thereby protected.
So the DOJ's original challenge could possibly be the basis for round 2 to get them completely deregulated.
This is exciting, but there is more to come.
Thank you.
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