Fully Digital Firearm Recordkeeping Protects Your FFL

FFLs have two choices when it comes to maintaining their federally mandated firearms transaction records. FFLs can go “old school” and do it all manually using physical paper 4473s and pen. Or they can step into the modern computer age and use technology to protect their FFL.

The latter not only protects your FFL and helps you maintain your compliance but also allows you to streamline your operations.

When you’re running a business, time is money, and the more efficiently you operate, the more money your business makes. The right choice seems simple, doesn’t it?

Staying in Compliance with ATF

Starting with the basics.

As an FFL you know the following, but it’s important to occasionally review these points that are critically important pieces of your day-to-day operation and compliance health.

• Every firearm that you receive and dispose/transfer to and from your business must be recorded in your Acquisition and Disposition Record, commonly known as the “Bound Book.”
• You are required to record who you received the firearm from and the date you took regulatory possession of the firearm.
• You are required to identify the firearm. How do you accomplish this? Glad you asked.
  • You must Identify the firearm with very specific information that MUST be taken off the firearm itself. Not the box, not the invoice, not your knowledge of firearms. This information must be taken directly from the firearm itself.The Gun Control Act of 1968 specified that firearms made as of the passage of this legislation must be marked with the information you are required to record.
    • Stay tuned for a future blog on how to recognize these markings. It sounds simple and can be, but it can also be a challenge, specifically on Pre-’68 firearms.
  • The markings that are required to be recorded are:
    • Manufacturer
    • Importer (If Any)
    • Model (If Any)
    • Type (Pistol, Revolver, Rifle, Shotgun, Frame/Receiver, etc.)
    • Caliber/Gauge
    • Serial Number
• This information then needs to be seamlessly transferred to or manually recorded on the ATF F 4473. If the information recorded in your Bound Book does not match exactly to the 4473, ATF will cite it as a violation.
• Every transfer of a firearm you make to a non-licensee (an individual who does not have an FFL) must be recorded with the completion of an ATF F 4473.  This involves you as the FFL (the transferor) as well as your customer (the transferee).
  • This form has over 90 specific pieces of information that must be filled out completely and accurately EVERY SINGLE TIME.
  • A background check must be executed with an FBI/NICS (or state POC) approval/proceed result, or the customer or transaction must have a valid exemption to the background check.
• Every 4473 you START must be retained for the LIFE of your business.
  • To review this new requirement, please see ATF Ruling 2021R-05F.
    • This ATF PowerPoint is long – but skip to slides 44 – 47 for specific information on the change to your record retention requirements.
  • There is no exception to this requirement, you must now keep every 4473 forever.
• Now, the firearm must be disposed of in your Bound Book and to the individual you transferred it to.
  • If you transferred to another FFL – no 4473 is required, but the disposition recording in your A&D book is still required.

These steps and requirements are wrought with pitfalls and compliance trip hazards.

If you are doing all this the old school way, you are setting yourself and your business up for a very unpleasant compliance inspection from ATF. Just because you did well on a prior inspection does not mean you will the next time.

In fact, ATF has stated that previous positive inspections are NOT an endorsement of your compliance health and have no bearing on your future inspection results. Remember, ATF can show up at any time on any day unannounced, once every 12 months. 

The ATF is more likely to conduct follow-up inspections sooner (shortly after the 12-month period) if you have violations, so having clean inspections ultimately means spending less time doing inspections and hosting ATF at your facility.

Using Technology Protects Your Business

Technology helps streamline the complicated A&D and recordkeeping process and protects your FFL compliance health.

“In a nutshell, you receive the firearm correctly the first time and that information automatically transfers to the 4473 and you know you have it right every time!”

There is a misconception that digital software is somehow less secure than paper. Nothing could be further from the truth. Specifically with 4473 Cloud, storing your 4473 electronically is—in every aspect of security—significantly more secure than paper forms. This applies to both internal and external access to your firearm records.

Internally:

• FFLs have complete control over who has access to their 4473s.
  • Ask yourself, where are your 4473s stored today, and how many employees or other random individuals have access to that space?
• Not only do you have control over who has access to your forms, FFLs have full control over who can do what with that access.
  • With several user level permissions, FFLs can allow “view only”, or give more seasoned employees and managers the ability to make corrections (when necessary).
  • These permission levels can be granted or removed with a click of a button.  Anyone with a pen can make “corrections” on your paper forms.
• Every interaction with a 4473 is tracked and recorded in an electronic chain of custody.
  • User and date stamps are kept for the life of your business.
  • If you store your 4473s in paper form – how do you know today who pulls or looks at (or photographs!) a 4473?

Externally:

• If you are storing 4473s physically, your customer’s PII is protected only by the strength of the lock on your front door and the door to the closet or office where your forms are kept.
• With 4473 Cloud – NO ONE outside of your company and your granting of approval to 4473 Cloud can ever access your 4473s and your customers’ critically important PII.
• During a compliance inspection – ATF IOIs will only have access to your 4473s during your business hours, and you have full visibility of how many ATF IOIs are in your ATF Audit Mode system at all times.
  • ATF can and will often ask FFLs to take records off your premises to complete their inspection.
    • The decision to allow this is up to you, the FFL.  However, you are NOT required to allow this to happen, and if you say no, you will know immediately if someone outside your store is looking at 4473s.
    • This is the control and peace of mind you deserve as an FFL.

These are just some examples of how digital storage is more secure. But, don’t forget natural disasters, a fire, or a disgruntled employee bent on causing your business harm.

4473 Cloud protects against all these instances, which hopefully never happen to your business but inevitably occur to many FFLs.

Thanks to the ability of these digital systems to run quick searches on firearms and 4473s by serial number, date ranges, and more, you save time and protect your records. Rather than ATF IOIs or Agents and/or your employees spending hours on end looking at, reading, and potentially removing and improperly refiling thousands of paper forms during internal audits or ATF serial number traces, 4473 Cloud allows rapid and precise location of only the relevant record(s).

Start protecting your business and your customers’ private information today. You can have a 4473 Cloud account created and start storing your 4473s digitally in less than 5 minutes.

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