Well, there's no telling what the FINAL memo is going to look like. I have a sneaking suspicion that the 2 week comment period is ONLY to see what holes people poke in the draft......holes that the final issuance will plug quite thoroughly.
No matter what you do, it's going to be a debacle. IF they decide to give away free stamps, you're going to see a LOT of folks take advantage of that.........along with the wait times. The ONLY reason that efile Form 1 is 'quick' is because there's no paperwork OTHER than the fingerprint cards. EVERYTHING ELSE is done in the digital world, most of that automated. Used to be about 21-ish days first email to final approval in hand. Throw 20K+ applications at the system, and you're looking at that turning into 12 months+, just like a Form 4 transfer.
Seriously, you need to believe that they will drag their feet on it awaiting Joe to come in and do as promised and simply outlaw them by executive order and thereby invalidate the 'free' tax stamp.......so that their workload drops off by 20K+ applications instantly and you can then pay your $200 to keep your gun, or modify it to a rifle, or be an outlaw.
Anyone who didn't see this coming FOR YEARS has had their head in the sand.