How many years’ worth of paper 4473s (that include multiple handgun sale forms, multiple long gun sales forms, error corrections and many other attached documents) do you have sitting in your warehouse? Years and years, totaling thousands of pieces of paper, stacked in rows and rows of cardboard banker’s boxes doing nothing more for you than collecting dust and making ATF traces as difficult as possible. Don’t worry, you aren’t the only one! Thousands of FFLs coast to coast have the same problem you do, and until recently, it was just part of being a retailer in the firearm industry.
That was until August 17th, 2022 when ATF released ATF Ruling 2022-1 allowing digital storage of ATF Form 4473s and all required supplementary documentation. ATF first issued permission, better known as an “approved variance”, to store 4473s digitally in 2019. Now you do not need an approved variance to leap into the 21st century and take your business fully digital. ATF Ruling 2022-1 allows any FFL to store 4473s in a digital format if the software used meets or exceeds the requirements in the ruling itself. Take note – there are 18 specific requirements in the ruling and simply saving a PDF on your desktop doesn’t cut the mustard.
Storing forms digitally is a wildly beneficial option for FFLs. It saves time, money, space and increases efficiency with regard to completing ATF traces and conducting internal compliance audits. That’s great but what about the thousands of records you have stacked away in your warehouse taking up valuable backstock space? Good news. ATF added guidance on what you can do with those records as well.
Specifically, in Ruling 2022-1 ATF states:
“FFLs who have paper Forms 4473 completed prior to, or after this ruling, may elect to digitally scan Forms 4473 older than 3 years from the date the firearm transfer occurred, the date the transaction was denied or cancelled, or the last date of entry where no sale or delivery of the firearm occurs, including supplemental ATF forms or documents from a transaction (multiple sale forms or documentation showing the exception to the nonimmigrant alien prohibition). The Forms 4473 must be scanned in an expeditious manner, and retained in the same manner as required in conditions 3-5, 7-8, 13, and 15 set forth for FFLs retaining electronically completed Forms 4473 in an electronic format.”
If you have 4473s that are 3 years or older, you can now scan them and store them digitally in a software that meets the overall 2022-1 conditions! Talk about a HUGE win for retail FFLs. I can distinctly remember working for the largest national retailer of firearms and our stores having to get forklifts to take pallets of 4473s off the shelf in the warehouse, and sort through banker’s box after banker’s box of 4473s to complete an FFL trace. What a waste of store resources and time! No matter the size of your operation you can simplify this process and free up valuable space in your store by simply going digital. Hundreds upon hundreds of FFLs are already doing this today and you should be the next.
Once scanned and digitally stored, trace requests go from a burden to a breeze. You can complete an ATF trace of a record from a decade ago in less than 30 seconds. Remember not completing an ATF trace within 24 hours is considered one the 5 deadly sins that can cause you to have your FFL revoked! Why take that risk?
If you are already using an electronic 4473 and bound book software, odds are 4473 Cloud is integrated with them already and you can start storing your 4473s digitally in no time. Even if 4473 Cloud isn’t integrated with your e4473 software provider, you can still start storing your 4473s digitally as soon as today! Of course, you still have to notify ATF 60 days prior to going to fully digital, but you can immediately start storing a digital copy as soon as today! All you need to do is click here to get started.
Still handwriting your bound book and using handwritten 4473s? Now is a great time to consider going digital in 2023. Your risk, especially in today’s regulatory environment where more FFLs are being revoked than ever before, is at an all-time high and there is no better way for mistakes to happen that doing old school paper records. There are a number of options out there to meet your bound book and 4473 needs. Use the links in the blog post above to contact them today to get a demo scheduled!
The benefits of going digital are endless but without a doubt one of the biggest benefits is getting those old, legacy, dust covered 4473s out of your store once and for all! ATF now requires you to keep every 4473 you start whether Transferred, denied by NICS or simply a No Sale for the life of your FFL. Technology to minimize the impact of that requirement is at your fingertips. Don’t hesitate, get started today and see firsthand the benefits of going digital!
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