It's not like Stringer Bell and Ray-Ray can just go in, file the paperwork and $25 registration fee. (YMMV in your state) Yes, you still have to pass the NCIS check. You just don't need the CLEO sign-off. Maybe AJ can answer it better.
The Grantor or Trustee who picks up the suppressor registered to an NFA trust is subject to a NICS background check at the actual time of transfer/handover. Maybe it's a grey area in the law/rules, but there's NO SOT/FFL who will not do one.
Of course, the whole thing is up in the air now. The new rule proposal Eric Holder just signed off on yesterday, it's still unclear if CLEO sign off's have been eliminated for everyone, making trusts moot for most people, or if CLEO sign offs have been added to trusts too. It's very unclear, and a FFL 07/09 SOT friend of mine and Monkeyleg's was talking with the ATF that very day getting his new business premises inspected/signed off on, and he said the ATF inspectors/agents had no clue as to what was going as of yet either.
There's all sorts of speculation and re-reporting flying everywhere over this. People pissed at NFATCA thinking they did this to us on purpose for some tin-foil-hat theories that "rich NFA collectors" wanted the NFA market made more difficult to enter into. (Exact opposite if this is bad, it'll reduce demand and liquidity and prices of pre-86 MG's and exotic/expensive DD's, not raise them...) , others who understand what NFATCA was trying to do to help us (and throw the ATF a bone by making trusts less attractive to reduce their paperwork load) but still pissed they just "didn't leave well enough alone".
And some like me still hoping there's a slim chance CLEO sign-off is still being done away with, and there's still lots of misinformation and FUD going on. I see a tiny chance that we may be going to universal CLEO
notification (like when you apply for an 03 C&R FFL) and CLEO
approval is still going away. Admittedly a very slim chance.