ATF compliance inspections, or audits, bring a certain level of stress to every FFL when an ATF IOI walks into your store.  How high your stress level rises is a direct reflection of how prepared you are as an FFL and the length of time your friendly neighborhood ATF IOI (or team of IOIs) spend in your store.  Fortunately, thanks to technology there are solutions available to you that can address both of these drivers of unneeded stress and sleepless nights.

As we have said before, it is only a matter of time until it is your turn for an ATF Inspection.  There is no “IF”, only “WHEN” will it happen.  On average you should expect ATF to visit you at least once every 3 – 5 years.  And, if you are new to the firearms industry you should expect the ATF to come verify your compliance with the regulations within the first three years you are in business.  If you haven’t had the ATF in your store in a while, now is the perfect time to start considering how quickly you can get yourself prepared for the inevitable day they arrive. 

ATF can, under the regulations of the Gun Control Act (GCA) of 1968. Inspect your compliance unannounced once every 12 months. When they show up unannounced, the Lead IOI (industry Operations Investigators) will identify themselves and let you, the Responsible Person (RP), know that they are there to conduct their inspection. They may be alone or they may have one or more additional IOIs with them based on the size of your operation.  What will they do when they get there and what should you do?

  • First and foremost, provide ATF with a well-lit comfortable place to conduct their inspection.  E.g., a conference room, or some private office large enough to accommodate their inspection team.
    • Keep in mind you are required by the regulations to allow ATF to conduct their inspection.  Not doing so is considered one of the Deadly Sins that will see you facing revocation!
  • Remember that ATF can and will ask for just about anything and everything under the sun when conducting their inspection.   However, you are only required to provide them with access to the documents specified in the GCA
    • If you do not know what you are required to provide or what you can respectfully decline to provide, you should contact an industry compliance professional or lawyer TODAY.  Do not wait.
  • ATF will ask for your Bound Book or “Open Entries” in your Bound Book to conduct an inventory audit.
    • This typically is a book to gun and gun to book match to ensure every firearm in your book is accounted for and every gun in your store is in your book.
      • PRO TIP:  You should be conducting regular inventory audits internally and we recommend you do so monthly at a minimum.  Don’t let ATF’s inventory check surprise you, you should already know your inventory is spot on!
  • They will ask for your 4473s and all related and required attachments to those 4473s, which does not include a copy of customer’s driver’s License.
    • They will do two very specific things with your 4473s:
      • First, they will review every form with a fine tooth comb and look for any and all potential errors on those forms.
        • Every 4473 has nearly 100 potential errors just waiting to be seen by an IOI.
        • Paper forms with no compliance guardrails are a minefield of errors!
      • Second, they match those forms to your bound book record of dispositions to ensure your book and your paperwork match.
  • They will also ensure you have all required documents posted in your store.
    • Your FFL, youth handgun safety poster, youth handgun safety pamphlets and any required state forms specific to selling firearms and/or ammunition.

This entire process can be time consuming for both ATF and most importantly for you as the RP on your FFL.  Your livelihood literally hangs in the balance the entire time they are in your store and with revocations at an all time high, and DOJ’s mandated zero tolerance policy, you feeling stress is well warranted and understandable. 

That’s the scary part but know that there is good news as well.  You can lower your stress; you can mitigate your risk and you can take steps that will make the day they walk in the front door just another day at the office! Those steps start with the company creating a culture of compliance.  In a nutshell, your team needs to know from the top down that compliance comes first in every and all transactions and that no one sale is worth taking any chance when a question arises on the validity of a transfer. That starts with you!

As previously mentioned, getting a professional’s point of view of where the health of your compliance program stands is worth every penny you will spend to have them make a visit.  Additionally, they will make recommendations on how to improve your current level of risk, even if you think you’re bulletproof today.

Lastly, but certainly not least, the simplest and most cost-effective measure you can take to ensure your FFL is compliant – TECHNOLOGY.  The regulations were written in 1934 and 1968, but that doesn’t mean you should still be running your business to the technology standards of 1968.  Do you still listen to music on an 8-track?

Paper 4473s and a pen are the gateway to a revocation hearing. Keeping a mountain of paper 4473s stored in your warehouse is the most inefficient way you can possibly complete an ATF trace request.  That is also a highway to hiring a lawyer and fighting for you business’ life in a revocation hearing.  Why take these risks?

First things first, invest in an electronic bound book and electronic 4473 software. There are numerous options out there and we did the initial leg work for you.  Use this article as your spring board into understanding which solution best fits your needs.  Eliminate 97%+ of errors typically found on 4473s and in Bound Books by ATF instantly.  Whichever solution you do go with, just don’t wait to do it.  As you look at the calendar, you already know your next ATF inspection is right around the corner and waiting only increases your stress level.

Next, thanks to ATF Ruling 2022-1 start storing your 4473 digitally.  Why print a 4473 that you just completed electronically, when in a click of a button, with no need for any IT work or development, you can send that 4473 into a secure digital storage solution like 4473 Cloud.  From signing up to storing your first 4473 digitally can happen in less than 15 minutes.  Feedback from our current customers shows that storing your 4473s digitally eliminates so many potential errors, many IOIs have told our FFL dealers as they are digitally reviewing 4473s “this is really a waste of my time, I am not going to find anything on these forms”.  Talk about a WOW moment for those FFLs.

Mitigate your risk, streamline ATF’s inspection process and last but not least, eliminate those stacks of paper 4473s that are floor to ceiling in bankers boxes or file cabinets in your warehouse.  Free that space up for much needed inventory backstock and in doing so complete ATF trace requests in seconds without the need to put on a gas mask to dig through the years of dust to find a form.  You can scan those legacy records into 4473 Cloud for a fraction of the cost it takes to “find” the paper form! 

No More Paper, No More Boxes, No More Dust!

Make the change today and bring your business into the 21st century!

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Travis Glover Feb. 21st, 2023

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