ATF Compliance Inspection. What to expect?

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ratski

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After Action on Compliance Review:

Some of what I learned. This may be rudimentary for most, but some of it was eye opening for me.

Bound book:

Under Type: Semi Auto applies to pistol and rifles. You need to differentiate in this column which it is. Doesn’t matter that the model number is an obvious rifle, has to be specified in type.

If you get multiple firearms from the same manufacturer: Quotes and arrows aren’t allowed. Each line has to be filled out in full. So if you get 10 S&W model 66s from the same distributor, Smith and Wesson has to go on each line with each serial number. Same goes for all the other columns like date, from whom received, type, etc.

In the From Whom Received column, it is OK to put the distributor’s name and their FFL number instead of hand writing the entire name, address, city, state, zip. If you do a lot of business with certain companies, rubber stamps are OK also.

If you are a corporation FFL and transfer a firearm to yourself, you have to have a 4473 for that.

You can have your 4473s files chronologically, alphabetically or by a form number (1, 2, 3, etc) If you have them files alphabetically it has to be a very strict alphabetical sort, AA, AB, AC, etc. Not all the As in one folder, all the Bs in another, etc. You can’t do alphabetical and chronological (example: all the year 1990 forms filed by alpha) without a written variance from BATFE.

I get a copy of the customer’s ID. Driver’s license, etc. I figure that the more information I keep, the better. I had been attaching that along with the ezcheck screen shot to the 4473s. Potential problem there is that if the customer’s address block does not match the address on the ID EXACTLY. Had one that the customer’s address was something like “xxx SW 8th Avenue”, but his driver’s license said “xxx 8th Avenue”. No “SW” on the driver’s license. My guess is that there isn’t a “NW 8th Avenue” so no one figured it to be a problem. It was here. If the driver’s license hadn’t been attached to the 4473, it would have been a non-issue.

If you find an error on a 4473, don’t correct it on the original 4473. Xerox the 4473 and make the corrections on the photocopy, then attach that to the 4473s. A while back, the address block asked for “county” as part of the address. A lot of people either didn’t see that or read it as “country” and put “USA”. I found a few where the “county” had been left off of the mailing address. Don’t correct it on the form. Don’t cross out “USA”.

NICS:

Don’t do the check until after customer has filled out and signed the 4473. You have to keep all of your 4473s that you run thru NICS. If you have a denied, that has to be files separately and maintained.

Don’t run a NICS without a corresponding 4473. I had been told that to keep my e-check active, I had to run at least one check every 90 days, even if it was on myself. I had just done that last week. The agent had a list of all my NICS check numbers and crosschecked them against the 4473s and wanted to know about the “missing” one. Had to print up the “Proceed” page with my name and the NICS number.

Make sure you have your Youth Poster up.

Make sure you have the Youth Handgun Act brochures.

Make sure you include the fact that you give the brochure to everyone who purchase a firearm when you do a verbal “what is your procedure from the time you get a firearm in stock to the time you sell it?” question.

All guns locked and/or secured. Trigger locks.

You have to have extra trigger locks available to customers.

Any personal firearms on premises have to be marked “Not For Sale” or ‘personal firearms” to differentiate them from inventory.

Something that really surprised me was that if someone brings in a firearm to you to hold for them, like for security reasons. You have to check it into the book and they have to do a 4473 to get it back. I had asked the question because a friend had asked me once about this. Their dad was getting a little “forgetful” and they were uncomfortable with the guns in the house. Wanted to know if they needed if I could hold them for them for a while. Agent said that if they brought them to my licensed premises, should be entered into the book and 4473s filled out and needed for them to get them back. Didn’t ask about if they brought them to my home instead.

You should have your sales tax permit. Used to be here that I could just go down to the tax office and do a casual report of sales tax. Few years back, several suppliers wouldn’t ship unless I had the sales tax number.

We went over a LONG list of “acknowledgement of Federal Firearms Regulations” paper. Two pages. The agent gave me a copy and we had to go over line by line every thing on the pages and I had to check off that it was covered. That alone took about an hour.

All and all, it took about 3 ½ hours. Probably longer than some, but it was after all, my first inspection in 18 years.

The agent told me that they are trying to inspect once every license cycle and can inspect once every 12 months, to include un-announced inspections. That would have been more of a pain as I had to re-schedule patients for the appointment, and then had to reschedule a few others because the inspection went long. Can’t imagine the interruption to a full time FFL business that could result from the unannounced visits.

All in all, I came out OK. No Orange jumpsuit at this time.

Long day though. AC was going out as the inspection continued and I had a teleconference afterwards that ran another few hours. Couldn’t run fans because of the noise. By the time I got out of the office it was over 85 inside. Went home and found out that the brand new AC we put in two weeks ago was out also.

Long day.

Didn’t think it would get any worse. This morning I got a call from my mother in Maryland. She and my dad were supposed to be in Las Vegas. Looks like my dad had a small stroke.

Man.


Dave
 

aestus

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Thanks for the information. I've been seriously considering getting an FFL and jumping into the firearms business part time and this information is gold. I'm sorry about your father.
 

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