Prior to the enactment of ATF 41P/F (on July 13, 2016) local Chief Law Enforcement Officers (CLEOs) had broad discretion in approving forms to transfer or manufacture NFA items. "Shall Certify" laws compel those CLEO’s to certify the form(s) of any applicant who is not otherwise prohibited from owning a firearm. The NFA Freedom Alliance worked to enact these laws in numerous states.

With the enactment of 41F/P on July 13, 2016 the need for "Shall Certify" legislation has essentially been negated.