What do you mean too late? You can still submit paperwork can't you? You just have to provide finger print and photo id right? So they can do background check on the people in your trust?
I believe you are correct.
The online eForm was down Monday & Tuesday (not surprised). The ATF did publish a note on Tuesday afternoon around 3:00 PM that they would accept a paper form 1. The note stated they would process the paper form pre 41P changes, if the documents were postmarked before the 13th. Needless to say I made a mad dash to post office on Tuesday to mail my paper form 1.