What’s the most important document to an FFL’s compliance? It could be argued that it is the Bound Book, but for the sake of today’s blog, it is the ATF F 4473. And, even if not for the blog, it is the 4473. What used to be affectionately called the “Yellow Form” is required to be completed for every transaction in which an FFL transfers possession of a firearm to a non-licensee. Which simply means, your customers.
The 4473 must be completed in its entirety and must be completed accurately, 100% of the time. Period. Full stop. Every form, every time, from start to finish, MUST be completed perfectly. Simple clerical errors can cost you your FFL. That is the reality all FFLs live in today. FFL revocations are still at an all-time high, and 4473 errors are a significant driver of that.
Here’s the good news. Completing 4473 properly every time is achievable. Through:
- Creating a culture of compliance within your business.
- Training your team on how to be compliant.
- Internal audit programs – inspect what you expect from your team.
- Using technology to mitigate your risk.
These four simple, effective methods will place a security blanket of knowledge and tools that will protect your FFL. Implementing these standards will make your next ATF inspection just another day at the office. A key portion of your training should revolve around attachments to your 4473s. Some attachments are required, and not having them attached to the 4473 is the same as not completing the 4473. You will get cited and could have your FFL revoked because of it.
Some FFLs choose to attach documents to 4473s that are not required.
- E.g., a copy of the Driver’s License (unless required by your particular state’s law).
Ask yourself this one question – what advantage does attaching a DL to your 4473 provide? Any? The short answer is no. It typically provides nothing more than potential evidence for the regulatory body of the firearm industry, the ATF, in the unlikely event you DID NOT verify the customer’s ID according to the regulations. You can attach anything you want to a 4473, but unless it is required by law, whether federal or state, it doesn’t do anything positive for your compliance health.
If you want to keep copies of DLs, register receipts, etc., consider doing so in a separate filing system away from your federal and state-mandated document retentions. ATF Ruling 2021R-05 now requires that you keep every 4473 that you start for the life of your FFL. Keeping additional files just makes what is already a burdensome level of record retention that much more complex and takes up that much more space.
Let’s look at some documents that are required to keep with your 4473s. They include:
- ATF F 5300.9A – Firearm Transaction Record Continuation Sheet.
- ATF F 3310.4 – Report of Multiple Sale or Other Dispositions of Pistols and Revolvers.
- ATF F 3310.12 – Report of Multiple Sale or Other Disposition of Certain Rifles.
- This applies FFLs in Texas, New Mexico, Arizona, and California.
- Exemption to the Nonimmigrant Alien Prohibition.
- Error Corrections to the 4473 after the transfer of the firearm takes place.
- State-specific permits or forms.
Pop Quiz: How many firearms can be transferred on an ATF F 4473 without the use of an ATF F 5300.9A addendum?
The correct answer is three. Once you surpass three firearms on a single transaction, you MUST do the following:
- Ensure the total number of firearms on line 6 of the 4473 reflects ALL the firearms being transferred on the transaction.
- Do not fall into the trap of thinking this line only applies to the three lines provided on the 4473 to enter firearm information in boxes 1 through 5.
- If you sell 7 firearms to a customer, be sure to write out “Seven” in line 6.
- If two or more of the firearms you are transferring on this transaction or in a combo of transactions in the last 5 business days are HANDGUNS – complete and submit ATF F 3310.4.
- See the instructions on the 3310.4, itself, on how to process this form properly and in a compliant manner.
- Attach a completed ATF F 5300.9A to the 4473.
- When you add the total number of firearms on the 5300.9A to the three firearms listed on the 4473, it MUST equal the total you indicated on line 6 of the 4473.
If you are using an electronic 4473 or e4473, be sure to check with your software provider to ensure it auto-populates and provides you with a copy of the ATF F 5300.9A. If you are still printing completed 4473s be sure your team knows to be on the lookout for this addendum and get it attached to the printed 4473 immediately. The last thing you want is for ATF to be looking at a 4473 that says five firearms were transferred, but only three of those firearms are represented on your paperwork.
If you are using digital storage for your 4473s (and let’s be honest, why wouldn’t you be), ensure the serial numbers for ALL the firearms you transferred are loaded into your digital storage software. Not being able to search for serial numbers violates ATF Ruling 2022-1.
There are logically two ways this data can make it into your digital 4473 storage software:
- Via an API with an integrated e4473; or,
- Via a manual upload process.
4473 Cloud provides both methods to FFLs. Our integration partners, FastBound, Orchid eBound, EZ Arms Keeper, and Rapid Gun Systems, pass all serial numbers on a specific transaction along with your 4473 and the 5300.9A across the API to your secure storage vault.
4473 Cloud scans and reads manually uploaded PDF copies of 4473s. Once the 4473 is read, the system populates all the serial numbers on the 4473 itself. Customers then must ensure they add the serial numbers on the 5300.9A they are digitally “attaching” to the 4473 they are uploading.
Either way, 4473 Cloud has you covered and allows you to confidently store your 4473 and ALL required attachments in one document file. Free of cardboard boxes, dust, and wasting your valuable retail backstock space.
Stop letting ATF live rent-free in your store. Start storing your 4473 digitally today!
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