ATF Headquarters has taken the position that there is only one proper way to forward disposition firearms from a bound book, like paper, to a new bound book system, like Easy Bound Book®.
- The September 2016 ATF newsletter (link current as of June 5, 2024) said to use the original acquisition date and other entry information from the former bound book as the Acquisition date and other entry information in the new bound book. (See the bottom right column of page 4 and top left column of page 5.)
- Historically numerous Field Divisions and industry counsel said that the proper way was to dispose of the firearm to the new book and to use the Acquisition Date in the new book as the date of transfer from the old book, as well as showing the firearm being acquired from the same license associated with the bound book.
- Now, the ATF HQ has asserted that the 2016 Newsletter has always been policy.
- Further, ATF HQ is not recognizing that other advice from ATF officers has been given over the years and is now issuing citations for those using the use the Acquisition Date in the new book as the date of transfer from the old book.
- If you have specific, written advice from your IOI or the DIO of your region approving the use of the Acquisition Date in the new book as the date of transfer from the old book, check with your IOI, DIO or legal counsel to verify that you are okay to leave your book as is.
- If you do not have specific, written advice; check with your IOI, DIO or legal counsel to verify that you are okay to leave your book as is or make correcting entries in your book to the original date; name; license or address of the one from whom you acquired the firearm. See the attached newsletter from September 2016 for more information, top of page 5 for electronic records.
This is the process to move from one ATF bound book to another, based on our interpretation of what we read in the newsletter:
- Disposition the firearm from the old book:
- Enter the date of the transfer to the new book.
- Enter the book name/number; page number; line number of the entry in the new book. Use Easy Bound Book and the record number for the entry in the old book.
- Record the Acquisition in the new book.
- Record the firearm description.
- Use the original date of acquisition; name and address, or name and license number from whom the firearm was received.
- You must disposition the firearm before recording the acquisition. The firearm can only be in one book.
- Retain the old A&D books. You must keep your original book(s) because they are your legally required original ATF records.
- Based on this process, if you need to make corrections, you will edit the Acquisition in Easy Bound Book, recording the data in 2) above.
We are not providing legal advice; we are not lawyers. Please check with your IOI, DIO or legal counsel to verify your best course of action. And, of course, get it in writing..
If you need help, please let us know and we will be happy to help.