We've spent a lot of time over the last few weeks trying to figure out exactly what the best way is to proceed with eForms being down.
The decision is complicated by several factors:
1) If you've been watching our ATF Wait Times page, you'll notice that paper forms have been making a major comeback. We went from getting approvals from last May up to last August almost overnight - and the times seem to be doing nothing but improving day by day.
2) Even though there are quite a few advantages to using eForms, the one most people are interested in is the increased speed. Over the last week, it's become increasingly apparent that the NFA Branch doesn't plan to expedite eForms in the same way going forward - so the wait times will be closer to paper forms. Having said that, it looks like paper wait times will quickly become more reasonable than they were.
On this note, keep in mind that many of the forms submitted from mid-October of last year through the time when eForms went down were submitted on paper. Since most of those eForms have already been approved & cleared out of the system - the paper forms should jump forward in time extremely quickly once they get into processing forms from last October.
3) We don't expect ATF 41P to be implemented - especially not in the near term; but, a lot of customers do have that possibility in mind. I can almost guarantee that waiting for eForms will not get current applications into the system by June if you're worried about that.
Based on everything we're hearing, we are going to change our default recommendation to submit by paper instead of waiting for eForms 2.0. After weighing all the data, it looks like that is the best way to go at this point. We'll continue to monitor this situation over the next few weeks and will post as soon as we get more solid data on eForms 2.0 going live.
Even with that recommendation, we're not forcing customers one way or the other. Once we review your submission information, you'll get an email from us asking which way you want to go - and we're happy to wait on eForms if that's what your preference is.