I’m not sure but don’t think that is the case. Think you have to do finger prints and photos on every form regardless of how long it’s been.
You are correct. I was thinking about this:
Q. If an application was approved within the preceding 24 months, are fingerprint cards and
photographs required to be submitted with a new application?
A. Yes. The 24-month exemption for providing supporting “documentation” refers only to the
documentation proving the existence of an entity, such as trusts or corporate paperwork. The Form
5320.23 with attached photograph and fingerprint cards are required for each person identified as a
responsible person for each submission in order to initiate the required background check. See
instruction 2 d. (4) and (5) on the Forms 1, 4, and 5.
When the rule was first being discussed, there were some who interpreted the change as you only had to submit once every 24 months (it wasn't clear).
All in all, I am still not a fan of this stupid rule change and am pretty much done buying until something changes.