01 / CONFIRM INJUNCTION COVERAGEDocument the protected transaction nexus
The injunction is party-specific. For a nonparty dealer or buyer, coverage depends on the applicable plaintiff, association membership, commercial-member status, customer relationship, item category, and the particular transaction. A state’s participation protects its agencies and political subdivisions—not every resident.
02 / SUPPRESSORS & COVERED AOWsThe Gun Control Act still applies
For a transaction actually protected by the injunction, the court did not enjoin Form 4473, NICS, acquisition-and-disposition records, marking requirements, or other GCA duties. State and local law can still require NFA registration or independently prohibit the item.
03 / SBRs & SBSsContinue the available approval pathway
The court did not enjoin 18 U.S.C. § 922(b)(4), which separately restricts an FFL’s delivery of an SBR or SBS absent Attorney General authorization. ATF has not published an alternative authorization mechanism; Form 4 remains the available pathway identified by current industry guidance.
04 / INVENTORY & NFRTRSeveral dealer mechanics remain unresolved
ATF has not issued a public procedure for removing an item from the NFRTR without Form 4, moving unregistered inventory between licensees, handling interstate movement under unenjoined § 5861(j), or supplying non-SOT dealers. Obtain written coverage documentation and transaction-specific legal guidance before departing from the ordinary NFA process.