SOT License Guide [2026] – Everything You Need to Know

May 1, 2026 | FFL, NFA | 115 comments

An SOT (Special Occupational Taxpayer) is an FFL (Federal Firearms Licensee) that makes or sells NFA firearms (silencers, machine guns, short barreled rifles, etc).

The SOT is a "taxpayer" because they pay a special annual tax in order to deal with a special class of firearms called NFA Firearms.

In this article I'm going to tell you everything you need to know about SOTs - but first, why should you listen to me? Simple, I'm a firearms attorney who has helped thousands get their FFL and become an SOT and I've represented and helped hundreds of FFLs stay out of trouble with the ATF.

SOTs are sometimes (incorrectly) referred to as someone who has a Class 3 License or even an SOT License.

These are incorrect because a Class 3 SOT is a type of taxpayer you can become (not an SOT license to have). The license held by an SOT is an FFL which is one of 9 types of FFL. And, an SOT can be one of three classes of taxpayer - either a Class 1, Class 2, or Class 3.

If this is confusing, don't worry - government bureaucracy is a mess. That's why we offer our Become an SOT course, to make everything simple.

The classes of SOT are:

  • Class 1 SOT - Importer of NFA firearms
  • Class 2 SOT - Manufacturer of NFA firearms
  • Class 3 SOT - Dealer of NFA firearms

Another way the term "Class 3" is often used is when someone is calling an NFA Firearm a "Class 3 Firearm." There is no such thing as a "Class 3 Firearm."

Instead, an NFA Firearm, or a Title II firearm, (more on these below) is imported by a Class 1 SOT, or it is made by a Class 2 SOT. Then, a Class 3 SOT is the dealer that sells it. Therefore, the firearm being sold by the Class 3 SOT came first from a Class 1 or 2 SOT.

We'll take a closer look at each class of SOT below.

SOT License - What is it?

SOT licence

A special Occupational Taxpayer ("SOT") is something that a Federal Firearm License ("FFL") holder becomes to engage in certain business activities with National Firearms Act ("NFA") firearms (also called Title II firearms) like short barreled rifles, silencers, and more.

To better understand what an SOT is, it's helpful to first understand what an FFL is.

Q: What is an FFL? A: An FFL, or Federal Firearms License holder, is a person or entity engaged in the business of making and/or selling firearms. FFLs are gun dealers or firearm manufacturers.

The process to become an FFL is fairly straight forward. However, there's a right and a wrong way to set it up.

SOT Licenses

There is a special class of firearms called NFA firearms (more on that next) that incur a special making and transfer tax each time the NFA firearm is made or changes possession. For most NFA Firearms, the transfer (or making) tax is $200.

This tax is paid by the maker of the firearm and, when it comes to transfers, the transferee of the NFA firearm (who it's going to). Unless you are an SOT, the tax is paid per firearm.

FFLs, in order to avoid the per item tax, and also to have special permission to make them, sometimes elect to become an SOT in order to pay a once-per-year tax that exempts them from the per item tax.

The once a year tax is only $500 for smaller FFLs and most home-based FFLs.

As you can see, there's a big benefit to becoming an SOT: with an SOT, you're already saving money once you get your 3rd NFA firearm in a year ($600, 3 X $200, vs $500 once) and if you'd like to make NFA Firearms as a Type 7 FFL, then you'll need an SOT by requirement.

What are NFA Firearms?

NFA Firearms are guns (silencers are legally considered to be firearms) that are regulated under the National Firearms Act of 1934.

NFA Firearms are also sometimes referred to as Title II firearms because the National Firearms Act is considered to be Title II of federal gun laws (The Gun Control Act of 1968 is Title I - even though it came about later). This is why an NFA item is sometimes referred to as a Title II Firearm.

NFA Firearms are:

  • Silencer (or suppressor)
  • Full-auto machine gun
  • Short Barreled Rifle or SBR (rifles with a barrel less than 16″ or an overall length less than 26″)
  • Short Barreled Shotgun or SBS (shotguns with a barrel less than 18″ or an overall length less than 26″)
  • Destructive Device (grenades and certain types of ammunition)
  • Any Other Weapon or AOW (pen guns, certain special handguns, etc.)
SOT NFA Firearm Silencer

In order to purchase an NFA item, an individual must purchase the firearm from an FFL/SOT and then apply for the transfer with the ATF.

There are special requirements for owning a machine gun.

Transfer approval times for individuals take up to 10 months (or sometimes longer). Whereas, the transfer times for an SOT are typically only a business day or two. This is just one of the reasons we like having an FFL and an SOT - SOTs can get NFA firearms in a matter of days.

SOT Classes

There are three available types of SOT called "classes." Each Class of SOT allows different activities with NFA Firearms.

Each SOT class and type of firearms business requires a specific FFL type.

Here's a table showing the SOT class, the purpose of that SOT, and the types of FFLs for each:

SOT Classes

SOT ClassPurposeFFL Types
Class 1 SOTImporting NFA FirearmsType 08 and 11 FFLs
Class 2 SOTManufacturing NFA FirearmsType 7 and 10 FFLs
Class 3 SOTDealing NFA FirearmsType 01, 02, and 09 FFLs

Now, let's dive a little more into each SOT class.

Class 1 SOT

A Class 1 SOT is the rarest type - this class of SOT is only for importing NFA Firearms and won't apply to most people getting their FFL.

However, it should help you to remember that there's no such thing as a "Class 3 Firearm" as there's a good chance that the NFA Firearm you're referring to actually started its life in our country through a Class 1 SOT.

This class of SOT receives NFA weapons from another gun dealer or manufacturer on an ATF Form 3 and typically sells them to a customer on an ATF Form 4 where the customer pays the transfer tax for the tax stamp.

In order to get a post-86 machine gun, a law enforcement demo letter is needed, unless the FFL from where the machine gun is coming is closing their SOT.

Class 2 SOT

A Class 2 SOT is the second most common class of SOT.

In order to manufacture an NFA Firearm, a Type 07 or Type 10 FFL must register as a Class 2 SOT.

The really cool thing about a Class 2 SOT is that it doesn't just allow an FFL to manufacture NFA Firearms, it also allows that FFL to also deal/sell those firearms.

A Class 2 SOT costs $500 per year if the company makes less than $500k a year. If the company makes over $500k a year, then the Class 2 SOT costs $1,000 per year.

Class 2 SOTs can make a machine gun whenever they want (no LE letter needed), however, machine guns are only supposed to be made for potential law enforcement or government sales/use.

Class 3 SOT

Class 3 SOT

A Class 3 SOT is the most common type of SOT and the only type that many people are aware of because this is the Class of SOT that your dealer is from whom you're purchasing an NFA Firearm.

A class 3 SOT may NOT manufacture their own NFA Firearms - they can only purchase them and sell them.

A class 3 SOT costs $500 per year for Type 01 and Type 02 FFLs.

How do I Become an SOT?

First, you need to get your FFL. Then, you can register as an SOT.

As a note, the special occupational tax is paid on a special SOT tax year which starts July 1 of each year. This means, if it's Spring time, you'd pay the full tax up until the end of June and then again starting July 1. In this case, it'd probably be better just to wait and start July 1 to save money.

If you'd like help in this process, please check out our courses on becoming an FFL and getting an SOT.

What does it Cost to be an SOT?

An SOT pays the registration fee once per year. The SOT tax year starts on July 1st of every year, regardless of when the FFL pays the registration fee.

If the FFL business makes less than $500,000 a year, then the registration fee is $500 per year. However, if the business makes more than $500,000 a year, then some SOT classes and FFL Types pay more.

Here's a table of the SOT registration costs by SOT class and FFL type:

SOT Registration Cost

FFL TypeUnder $500kOver $500kClassYears
Type 01$500$50031
Type 02$500$50031
Type 03n/an/an/an/a
Type 06n/an/an/an/a
Type 07$500$100021
Type 08$500$100011
Type 09$500$100031
Type 10$500$100021
Type 11$500$100011

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115 Comments

  1. John Doe

    If an SOT makes or acquires NFA items, do all the items need to be surrendered when they retire?

    Reply
    • John Doe II

      Unless they can be legally transferred, they are to be destroyed by the ATF.

      Reply
  2. Jon hawley

    Are FFL’s and SOT’s transferable to other states say, I became an FFL with SOT in one state but ended up moving to another state, would I have to reapply?

    Reply
    • Ryan

      You wouldn’t “re-apply” but you would have to file an address change with the ATF.

      Reply
      • Lawrence pasoni jr

        Your a great man thank you …im native to america and stripped of my knowledge on the rights we N/A own by and the land we should be protecting. With any means or resource to provide and secure our family. Religon and fellow partners.friends. acquaintances. From. Bully’s and unfair justice from keeping the peace.

        Reply
      • Corey

        Can a SOT be paid for at the same time that the FFL application is sent in?

        Reply
        • Ryan

          No, you’ll need your FFL number as part of the application. We cover the steps on how to do this in our courses.

          Reply
  3. Davon Powell

    What is required of me if i want to manufacture ammo only

    Reply
    • Ryan

      At a minimum, a business intent, an appropriate location (zoning), and a Type 06 FFL. However, there’s a lot more to consider that we cover in our course if you need help.

      Reply
  4. Todd Carlisle Pearson

    Is the process still in going to the ATF website, getting your two 5320 forms, getting fingerprinted, having the local sheriff, chief of police, or DA sign off on it then mailing it in with the $200? Or am I wrong?

    Reply
    • Ryan

      If you’re referring to getting an NFA firearm via a Form 4, you’re mostly right (there’s plenty of considerations to consider). However, if you’re talking about how to become an SOT, the info is wrong.

      Reply
    • Herbert Antonio Hidalgo

      Question how can we disband the NFA

      Reply
  5. Dan Hansinger

    Is having you SOT similar to the FFL in that you can purchase for personal use also, or is it only to allow for sales/transfers? I am interested in getting my FFL & SOT, but I want to benefit by acquiring some personal items also. Is it as simple as a “transfer” as referred to elsewhere on this site?

    Reply
    • Ryan

      Good question – might be a bit too much to get into here. Our courses definitely explain all this, though.

      The short answer is this: the FFL is the license that allows you to make/buy/sell guns and transfer them. Being an SOT is a tax status that allows you to avoid the per-item NFA tax and allows certain business activities with NFA items. So, an FFL is what is needed first. Then, you can become an SOT to work with NFA stuff. The transfer process for NFA Firearms is much more involved than standard firearms.

      Reply
      • Tyler

        Related to this, if I got a FFL and Class 2 SOT then starting making suppressors to sell to my friends, would they still have to pay the $200 tax stamp and get it registered in their name?

        Reply
        • Ryan

          Yes.

          Reply
  6. Bacchus

    If you were to apply and receive a FFL 07, would you need to apply for both a SOT 2 AND a SOT 3? A SOT 2 will give you the ability to manufacture it but does it also give the ability to sell what you manufacture as well? Or do you need a SOT 3 for that on top of it?

    Reply
    • Ryan

      Good question. In most cases, you’d only need a Class 2. We cover the differences in our courses.

      Reply
    • Adam F

      SOT2 also allows you to sell.

      Reply
      • Ryan

        Correct.

        Reply
  7. MARK JANUSZ

    HI Ryan, So First Get The FFL Then Apply For Slot 2? I can Build/sell And Transfer Firearms?

    Reply
    • Ryan

      Yep! We walk through each step of the process in our courses. You may not need to be a Class 2 SOT – it depends on what kind of firearms you intend to make.

      Reply
  8. Alexander moon

    Do you need an SOT if your a private seller/ manufacturer that won’t deal in special NFA items like SBRs and suppressors?

    Reply
    • Ryan

      No. Being an SOT is ONLY for NFA Firearms.

      Reply
  9. Joe Borges

    We have a type 7 FFL and engrave firearms for the larger gun companies. The gun companies would like us to start engraving silencers for them now. Would the Type 7 FFL be enough to be able to receive, engrave and ship back or would we need to add an SOT 2 to our FFL to be able to do that?

    Reply
    • Ryan

      You MUST be an SOT to work with NFA Firearms (like silencers)

      Reply
      • Joseph Borges

        Thank you so much. You have put together an incredibly informative product here and I look forward to continuing learning.

        Reply
        • Ryan

          Thanks, Joseph!

          Reply
  10. Davide Alessio

    Hi Ryan. I’m a permanent resident in the USA and an Italian citizen.
    I want became an FFL 07 (but manufacturing will be limited to no NFA items) and FLL 08 (importing regular gun and if requested NFA items). So the SOT is just to buy and resell (and import) NFA items because manufacturing will be limited to assemble parts of semiauto guns, that I will buy and resell. So the 2 questions:
    1) is it possible to combine with the FFL 07 a SOT 3 (not 2) and with the FFL 08 a SOT 1?
    2) Or the SOT 1 is good for both: import NFA and/or buy and resell NFA items?

    Thank You

    Reply
    • Ryan

      Thanks for reaching out, Davide! I think you’re going to want a Class 1 and Class 2 SOT – we explain this in our courses.

      Reply
  11. Shaun Carrouth

    I applied for My class 3 SOT and took your course, Now it’s almost May. If it comes in before June will I have to pony up another $500 right off the bat?

    Reply
    • Ryan

      It depends on which tax year you applied for.

      Reply
  12. Landon Luebke

    Does getting a class 2/ 3 SOT allow me to buy a already built full auto gun from company. For example a M249 Saw from FN’s website or store?

    Reply
    • Ryan

      It sure does! There are some extra steps, but that is how anyone who has a machine gun made by someone else got that machine gun.

      Reply
  13. Johnathan

    Ryan, I have had my SOT for several years now (07 FFL as a corporation) and acquired several suppressors during that time. I would like to drop the SOT. It is my understanding that under the NFA handbook; 14.2.2 Corporations, partnerships, and associations going out of business. I am able to keep the suppressors even if I drop the SOT as long as the corporation remains in business. Is this correct?

    Reply
    • Ryan

      Correct.

      Reply
  14. Jesus Ochoa

    I am attempting to start a business with an FFL type 1 and also get a class 3 sot would a DWI (misdemeanor) bar me from getting either?

    Reply
    • Jackie

      Hey Jesus! The short answer is that prohibited persons include anyone convicted of a crime which was punishable by over a year in prison, regardless of the sentence handed down. Ryan delves into this topic in the Get Your FFL start-up guide but you can learn more about it from him in a couple other ways also: Trigger Words Podcast – Episode #4 / Prohibited Persons & a RocketFFL article he wrote – “Prohibited Persons / Firearm Possession“. Hope this helps!

      Reply
  15. John

    Do Type 10 FFLs with their Class 2 SOT still require an ITAR license if they are not manufacturing suppressors or fully automatic weapons after the March 2020 revisions of the USML?

    Reply
    • Ryan Cleckner

      There are some other changes to ITAR that should be considered here. We cover this and more in our ATF compliance course.

      Reply
  16. Mike

    If I am an #7FFL SOT (live in California), manufacture a legal single shot AR pistol but want to use 16 inches barrel- this makes it “any other weapon” from my understanding.

    Question 1. I make the above, file it as AOW – I pay $200 then whoever buys it also pays $200?

    Question 2. One filed and approved, Can the above be both be legally a single shot AR pistol and switch to a semi auto 16 inche barrel?

    Someone asked:

    Related to this, if I got a FFL and Class 2 SOT then starting making suppressors to sell to my friends, would they still have to pay the $200 tax stamp and get it registered in their name?

    Your answer: YES

    Reply
  17. Richard Stein

    Thank you for the information, and very extensive website; but, hard to trust a man who has a seemingly loaded rifle with his finger on the trigger and a boastful smile. I would change the picture if I were you….

    Reply
    • Jackie

      Hey Richard. Glad the information was helpful to you! Not sure if the man in the photo is trustworthy or not; it’s just a generic photo of a man working at a gun shop.

      Reply
  18. Jeffrey A. Stevens

    I’m still a little in the dark about full auto guns. I thought that once no more full auto weapons could be imported and here is where I lose the train of thought, no more full auto weapons can be manufactured in the U. S. Please tell me if attrition wipes out the full auto weapons that are already here, no more of them can be imported or made. If You can enlighten me, I surely appreciate it. Sincerely, Jeff Stevens

    Reply
    • Jackie

      Hey Jeffrey. The only way to acquire a post-’86 machine gun is as an FFL/SOT with a LE/Demo letter, or if it’s obtained from a going-out-of-business FFL. An 07/02 can manufacture one and notify the ATF afterwards with a Form 2; but keep in mind that manufacturing items on the USML (regulated by the State Dept./ITAR), requires DDTC registration. Ryan covers this topic in-depth in our Get Your FFL start-up course, and for free on our blog – “Who Can Own a Full-Auto Machine Gun“.

      Reply
  19. Bret Getzel

    I’m a retired vet wit ha tour in Afghanistan and interested in owning a fully automatic AR 15 similar to the M4 I carried in Afghanistan. I would only trade a couple of guns a year and have no interest in building or importing. Based on the checklist, I would meet the criteria for the FFL. The suppliers I’ve networked with have said I need a demo letter along with the FFL before they’ll sell to me. Can you give me direction as to the best route to go as I’m trying to avoid making a costly mistake and investing considerable time only to find that I’m not able to buy the firearm I’m interested in purchasing. Thank you in advance.

    Reply
    • Ryan Cleckner

      Yes, to get a post 1986 machine gun as a dealer, you need a “demo letter” from an LE agency – these are very common and how every dealer gets their machine guns. However, if you’d like to just convert an AR-15 to full-auto yourself, you can do so as a manufacturer with a Type 07 FFL.

      Reply
      • Bret Getzel

        Thank you Ryan.
        Let’s assume that I get the Type 3 FFL and pursue the purchase a fully auto AR-15 and have the demo letter. Do I also need the SOT and then be expected to pay the $500 annually to maintain ownership the firearm?

        Reply
        • Ryan Cleckner

          You won’t get a machine gun with a type 3 ffl.

          Yes, you’d need to be an SOT and maintain it.

          Reply
  20. Peyton Mulder

    I want to open a shooting range and buy machine guns for people to rent (strictly on the range). I know I need an FFL 1, would I need an SOT 3 for this?

    Thank you!

    Reply
    • Ryan Cleckner

      Yes – and a LE demo letter for each. However, some nuances exist that we cover in our courses.

      Reply
  21. Aaron Early

    I already have a Type 7 FFL. I want to get an SOT but I also want my very close and trusted people to be able to use my NFA items. Is it possible to become an SOT but also put those people on it or in a trust so we can all share NFA items?

    Reply
    • Ryan Cleckner

      No – the firearms are either possessed by the business or they can be personal and be put into a trust.

      Reply
  22. Matt Harris

    When your SOT expires what are you required to do with suppressors for example if they belong to you?

    Reply
    • Ryan Cleckner

      This depends on how your FFL is setup and whether they really belong to you or the FFL company.

      Reply
  23. Derek Kamm

    2 questions….

    1. What are the odds on a scale of 1 to 10 that I can obtain an FFL & SOT in Suffolk County New York?

    2. Could I keep certain NFA items for me personally that even though I am in NYS

    3. Do you guys offer any type of concierge service acquiring in NYS & how much ?

    Reply
    • Ryan Cleckner

      1. No way for me to know your particular circumstance. Plenty of FFLs in Suffolk.
      2. Likely not.
      3. We can help – please email us at info@rocketffl.com

      Reply
  24. Kevin Lindsted

    Ryan, hello sir. Can you tell me if an 07/SOT needs a Law letter for an NFA transfer?

    Thank you.

    Reply
    • Ryan Cleckner

      Yes, a Law Letter is needed to acquire a modern machine gun made by another FFL. However, you may make your own without a Law Letter.

      Reply
  25. JB

    If I want to open an FFL type 7 with a class 2 SOT with a friend, and we base it in his state, what are the laws for me working on/having in my possession SOT firearms in my own state.

    Reply
  26. James R Wallace

    If I don’t renew my SOT do I get to keep any inventory that are on a form 3 ?

    Reply
    • Ryan Cleckner

      That depends on how you set up your FFL and which type of NFA firearms we’re talking about.

      Reply
  27. Jaime Saenz

    So if I get a couple suppressors and machine guns for Myself as a FFL and SOT class 3 permit holder? And my business closes in like 3 years am I still allowed to own them????

    Reply
    • Ryan Cleckner

      It depends on if you set up your FFL properly for the silencers. For the machine guns, no, you may not possess post-1986 machine guns if you’re not an active FFL/SOT.

      Reply
  28. Mark Andrew Garcia

    I purchased a G.R.A.D. knife pistol 22L.R.and it was sent to my FFL. At my FFL I was advised that my item fell under the class 3 SOT and a form4 had to be filed. Together we filed form 4 and I mailed in a check for $200.00 for a stamp that was well over a year ago and I still have not seen my stamp or me G.R.A.D. knife pistol. My question is this normal time period and is there anything I can do to help expedite the matter.
    I talk to my FFL, and he said just to wait. I asked if I could call to see where I was on the list, and he stated that if I call that it would take longer. This all sound crazy to me and it just doesn’t sit right in my head. I have my CCW I’m 100% disabled Vet and I collect knives. I don’t know If you can help, I just don’t know here to turn or should I just wait. Thank you very much,

    Reply
    • Ryan Cleckner

      You can and should call the NFA branch to check on the status.

      Reply
  29. Brandon

    I have my 07-FFL and just got a Class 2 SOT.
    I think I am ready to start my first build. What forms do I need to file?
    Do I need a Law Letter?
    Thank you

    Reply
    • Ryan Cleckner

      No law letter needed – that’s one of the best parts of being an 07/02 making your own machine guns. We cover which paperwork, how to file, and when in our ATF Compliance course.

      Reply
  30. Alexander

    I am a FFL Class 7 SOT 2. Can I travel to another State and take SBR / NFA select fire weapons without informing the ATF?

    Reply
    • Ryan Cleckner

      This depends on if they are business firearms on your FFL and for a bona-fide business purpose.

      Reply
  31. John

    As an 07 , 02 SOT holder , can we have a “Demo”silencwr that is kept in the shop but is taken out to be used?

    Reply
    • Ryan Cleckner

      Yes, you can have demo and testing firearms.

      Reply
  32. James Hart

    As a NFA SOT Class 3 Dealer how do I convert a pistol to a short barrel rifle
    What forms do I fill out

    Reply
    • Ryan Cleckner

      We cover this, and a lot more, in our ATF Compliance program.

      Reply
  33. Louis Hernandez

    Are all FFL dealers required to have an SOT? (No matter the State or the Territory)

    Reply
    • Ryan Cleckner

      No – an FFL only needs to become an SOT if they want to work with NFA firearms (machine guns, silencers, etc)

      Reply
  34. Brad

    Would a Class 7 FFL and a SOT 2, allow me to take an existing receiver, manufactured by another manufacturer, and build it out as a full auto NFA item, and then combine it with a separate, NFA item (suppressor) also manufactured by another SOT 2 manufacturer, to eventually demo and sell to LE/Gov’t? Or, would all parts need to be self-manufactured?

    Reply
    • Ryan Cleckner

      Yes, that’s exactly how many do it.

      Reply
  35. Daniel

    Mighty helpful information

    Reply
  36. Daniel

    Is a SOT required if one gets an 97 license?

    Reply
    • Ryan Cleckner

      I’m assuming you meant a Type 07 license. Becoming an SOT is required if you want to work with NFA firearms.

      Reply
  37. chris umstead

    so as an 07 ffl, if i got an SOT 02 i could build and sell but not buy and sell assembled correct? Comfused between class licenses. Will probably end up in one of these classes.

    Reply
    • Ryan Cleckner

      I hope you do take a class – there’s a lot to learn here.

      You can buy and sell assembled firearms as a Type 07 FFL.

      Reply
  38. E.L. Ingram

    Do I still have to register with ITAR to possess a class 7 FFL with a Class 2 SOT uder the new ITAR requirements?

    Reply
    • Ryan Cleckner

      You only have to register is you are manufacturing or exporting items under ITAR control. This used to be all rifles and handguns but is now a much smaller list.

      Reply
  39. ty

    If I already have my SOT 3 FFL dealer what is the easiest route to obtaining SOT 7 so I can assemble pre ban parts kits? Also is it true that you have to have a cnc machine before you can get licesnse?

    Reply
    • Ryan Cleckner

      You would need a Type 07 FFL to be a manufacturer and then register as a Class 02 SOT. No, it is not true you need ANY machinery/equipment prior to getting a license.

      Reply
  40. Matt Zullo

    I am training to be a gunsmith and I’ve signed up for your getting an FFL and becoming an SOT courses (just a couple lessons in so far). I want to become an SOT to work on/do transfer of NFA firearms. I also want to be able to “manufacture” AR’s and 1911’s to sell. My concern is ITAR. If I got a type 7 FFL and became a class 2 SOT, would I be subject to ITAR and get hit with that large annual ITAR expense if I didn’t manufacture any NFA items or could I manufacture them without being subject to ITAR so long as I didn’t export them? Should I apply for both type 1 and type 7 FFL’s and become a class 3 SOT?

    Reply
    • Ryan Cleckner

      You would only be subject to ITAR if, and only if, you made firearms or products covered by ITAR. This used to include all rifles and handguns, however, now only includes a much smaller list of firearms – things like NFA firearms and machine guns.

      Reply
  41. Brandon

    As an FFL, if my SOT is expiring do I have to renew it to keep the NFA items I have on my books, or only if I intend to acquire more?

    Reply
    • Ryan Cleckner

      If you intend to engage in business activity with those NFA firearms, then an SOT is needed. However, if not, you could let the SOT expire and the licensee could keep the NFA firearm (post-86 machine guns exempted)

      Reply
  42. Steve Harris

    I am interested in becoming an FFL and obtaining an SOT; however, I live in California and don’t want to invest the time and money to begin this process if California DOJ isn’t going to allow it. I know that I can get an 01 FFL, but, can I get an SOT in California?

    Reply
    • Ryan Cleckner

      There are MANY SOTs in California. 🙂

      Reply
  43. Arghya

    What additional requirements need to be fulfilled for FFL 07 / SOT 02? I heard ITAR registration and EIN from IRS. Anything else?

    Reply
    • Ryan Cleckner

      ITAR registration is very misunderstood and common misinformation online. You only need to register under ITAR in very limited circumstances – most 07 manufacturers no longer need to register. We break down the details in our courses.

      Reply
  44. Zach

    I am currently in the process of prepping my type 07 FFL paperwork (following along with your course), and was curious to know if a class 2 covers the purchase and sale in the same manner as a class 3. To me, if I’m manufacturing them for military use, they still need to be bought. So, does this class 2 cover the sale of them? Or will I need to pay both taxes? I think this will factor into which one I get first.

    Reply
    • Ryan Cleckner

      Yes, an 07/02 can purchase and sell just like an 01/03 does.

      Reply
  45. Don

    Can an 02 SOT purchase Class 3 items?

    Reply
  46. Rip

    Can you pair a type 3 FFL with any SOT types?

    Reply
    • Ryan Cleckner

      No, the Type 03, although it is technically an “FFL,” isn’t an FFL for business purposes. I think it would make things easier if the ATF just called it a collector license.

      Reply
  47. confused

    so if you’re an attorney, can you explain how a supressor (not silencer) is a firearm? i’m confused

    Reply
    • Ryan Cleckner

      Yes. What you’re referring to as a “suppressor” is legally defined as a “silencer.” And, the federal definition for a firearm has four parts – one of which is “silencer.”

      Reply
  48. Raul Benitez

    I live in the state of N.Y. with a FFL class 7. Can I get my S.O.T. to mfg or buy NFA items to sell out of state ?

    Reply
    • Ryan Cleckner

      I don’t know all of the details of your particular situation but, yes, there are MANY SOTs in the state of New York.

      Reply
  49. John Snipes

    What are the ITAR requirements If I become an 02 SOT if I do not import or export NFA items?

    Reply
    • Ryan Cleckner

      ITAR applies to all manufacturers of items that are covered by ITAR – even if you never intend to export anything. The good news as this is no longer most firearms and is only a limited group of guns.

      Reply
  50. Robert Moody

    Hi, I already have an 07 FFL. I would like to have an SOT to be able to handle and sell supressors. I dont plan to manufacture any, just be able to order, and transfer them. Can I do that with the class 2 SOT, or will I have to have a class 3? Can I obtain a class 3, with an 07 FFL, or will it have to be a class 2. Thanks for the info. Bob

    Reply
    • Ryan Cleckner

      These are great questions, Bob – I go into this and a lot more in the FFL/SOT courses (and especially in the ATF compliance courses at FFLSafe.com)

      Reply
  51. Bruce Retterath

    If Machine Guns, Binary Triggers are Illegal in my state, and I have an FFL and SOT can I have a Machine Gun and a binary trigger?

    Reply
    • Ryan Cleckner

      Maybe – most state laws that ban certain guns have exemptions for FFLs.

      Reply
  52. Chris

    As a Class 2 SOT owner, can i still purchase and sell NFA items from other dealers? Or am
    I limited to only selling what I, myself, manufacture?

    Reply
    • Jennifer

      The really cool thing about a Class 2 SOT is that it doesn’t just allow an FFL to manufacture NFA Firearms, it also allows that FFL to also deal/sell those firearms. You can buy from other dealers/manufacturers too. We cover all of this in our courses.

      Reply
  53. Dewon Rodgers

    Hello, Ryan I was reaching out to see upon the paper work is it a fee that you or your team does the applications for your clients to minimize the mistakes? If so I’d definitely like to speak more etc.

    Reply
    • test

      We offer an online course that walks you through the entire process yourself. You can hire Ryan as your attorney to do the process with/for you but that’s a lot more expensive.

      Reply

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