It all boils down to- have a trust if you expect others to use without you present - no trust needed if you don't let them out of your sight or your own safe. They transfer free to your heir after death with or without a trust.
No one has been prosecuted or charged for letting someone not on the trust use the nfa item while in the presence of the stamp holder.
Before the recent revision a trust saved a lot of time and hassle, not so much anymore.
I filled a form 4 today for another suppressor and talked to the ffl for a while about both. He is seeing form 4 individuals clear in 4 to 5 months and trusts are upwards of a year.
Personal choice, but the only benefit it's for people who want to share nfa unsupervised. It's not a loan if you never leave it alone with someone else.
This is where the problem is, it's just subject to different interpretation as I posted earlier on it's definition. I just prefer not to be the test subject on this.
The only difference before 41F and now is that if you purchase a new NFA item, you need prints. If you don't purchase new items, you can add/remove anyone from the trust w/o the need for prints.
Or am I speaking out of my ass again?