What is Multiple Sale Reporting? & How to Stay in Compliance!

ATF requires notification of certain transactions that may take place at your FFL. There are two defined transactions that you must notify ATF about if they take place.  We will discuss both and want to emphasize there are different requirements for each, so don’t assume one is the same as the other. 

First, let’s discuss the forms that are used when notifying ATF. 

• ATF Form 3310.4 – Report of Multiple Sale or Other Disposition of Pistols and Revolvers. 

• ATF Form 3310.12 – Report of Multiple Sale or Other Disposition of Certain Rifles. 

Report of Multiple Sale or Other Disposition of Pistols and Revolvers 

This form is required to be completed by FFLs and submitted to both local law enforcement and ATF for transactions in which an unlicensed person (your customers that do NOT have an FFL) acquires two or more handguns from your FFL during a consecutive five-day period. This may happen on one transaction or anytime during those 5 consecutive days. It may also happen multiple times within the five-day period. Additionally, the five-day period resets upon the latest handgun transfer date.  

Take note, the requirement to report only applies to multiple pistols and revolvers. Frames and receivers are not pistols or revolvers under the definitions in the Gun Control Act of 1968, nor is an “other” firearm such as the Mossberg JIC. Knowing the firearms that qualify for completion and submission of ATF F 3310.4 is solely the responsibility of you, the FFL. Once you recognize a transaction or a combination of transactions meet the reporting requirements, you must: 

• Complete ATF F 3310.4 accurately and completely. 

• Submit a copy to the CLEO (Chief Law Enforcement Officer) where your store/FFL is located. 

• Submit a copy to the ATF per the instructions on the form itself. 

• Keep a copy and attach it to the ATF F 4473 in which the second or triggering handgun was transferred. 

This must all be done by the close of business the day the second or triggering handgun transfer takes place. If a customer buys two or more handguns (any combination of pistols and revolvers) at the same time, the ATF F 3310.4 must be completed and submitted the same day.  If the second handgun is purchased on any day within the five-day period, the ATF F 3310.4 must be completed and submitted on the day the second (or more) handgun was transferred. If the same customer comes back within the following five-day period, you will need to complete and submit another ATF F 3310.4. Therefore, it is important to understand that you may have to submit multiple reports for the same customer over the required/defined timeline. 

A couple of points to keep in mind when it comes to completing and submitting ATF Form 3310.4:  

• This form applies to all FFLs in all states.  

• Your local law enforcement office may tell you that they do not want these reports, submit them anyway.  

Regardless of your local CLEO’s willingness to accept these reports, you are required to send it to them. What they do with these reports once you have sent the document to them is up to the LE office. Just be sure you meet your requirement to submit it.  

Report of Multiple Sale or Other Disposition of Certain Rifles 

This form is required to be completed and submitted to ATF by FFLs in certain states who transfer two or more rifles that meet certain defined characteristics to an unlicensed individual during a consecutive five-day period. So, which FFLs and which “type” of riles does this apply to?  

FFLs that are in “border” states are required to use ATF F 3310.12. 

• States subject to ATF F 3310.12: 

• Texas 

• New Mexico 

• Arizona 

• California 

• Rifles subject to ATF F 3310.12: 

• Semi-automatic.  

• Larger than .22 caliber (including .223/5.56 caliber). 

• With the ability to accept a detachable magazine. 

The rifle must meet all three of these defined characteristics to trigger the use of the ATF F 3310.12.  If you are in one of these four states and you transfer two or more rifles that meet the definition of “certain” you are required to complete and submit ATF F 3310.12.  

The reporting requirements in and of themselves are slightly different as well. When submitting your completed ATF F 3310.12 you are ONLY required to notify ATF.  

The requirement to notify your local CLEO does NOT apply to 3310.12. 

The requirement to submit a new 3310.12 for each qualifying rifle transfer within the five-day period does apply.  As does the timeline of doing so on the same business day the triggering transaction takes place. Additionally, the requirement to keep a copy of the ATF F 3310.12 with the 4473, in which the second or triggering transfer also applies.  

While there are subtleties between the two reporting requirements and the forms themselves.  It is important to take note that not completing either as instructed on the forms themselves and within the defined deadlines defined by ATF can cause you big issues during an ATF inspection. How big?  Up to and including revocation of your FFL.  

Conclusion 

Knowing what is expected of your FFL is half the battle. Implementing software and/or operational processes to ensure you catch all the qualifying transactions is the other and most important part. Software not only makes this process easy, but it also can ensure these transactions don’t slip through the cracks. Continuing to process paper 4473s and transactions in your shop is a recipe for revocation of your FFL. Don’t become the next statistic on ATF’s revocation mantel. Get started with an electronic bound book and 4473 today and complete your migration from paper by storing your 4473s digitally with 4473 Cloud. Click here to get the ball rolling!

Get started today - It's free for the first 30 days!

Get Started