Please check with your IOI and/or legal counsel before beginning this process to get the guidance you need for procedures in your region. The procedures below were confirmed by two Regional and National ATF offices. Do remember that 2021R-05F is in legal limbo and that may change these practices. We are not providing legal advice, only normal best practices gleaned from hundreds of conversions.
First, a serial number may only exist in one ATF bound book at a time. In other words, you may not enter an acquisition into a bound book while it exists as an open acquisition in another book. This presents a problem since the ATF wants the line number of the new record on your disposition record. We can help you solve this and other problems.
Is the process important? A little story can answer the question. Someone came to us with this story and asked about switching to Easy Bound Book®. They switched from one electronic bound book to another and did not dispose the on-hand inventory in the old book to the new book and then were audited. The ATF IOI declined to look at the new book because of all the undisposed Acquisitions in the old book. The FFL had to reconcile all the transactions in the old and new book and present all the documentation to the IOI to clear up the missing firearms that were sold and disposed of in the new book. So, yes, proper procedure is important.
So, with that in mind, here are the steps for changing to a new ATF bound book.
- Verify that all the on-hand firearms in your bound book are in your inventory and vice versa.
- Clean up any discrepancies now.
- Select a startup date for your new book.
- Use this as the acquisition date from your old bound book.
- Use this as the disposition date in your old bound book to your new bound book (Easy Bound Book®).
- Dispose of the firearm in your old book (before acquiring it in Easy Bound Book).
- Use the date you start Easy Bound Book as the Disposition Date.
- Dispose the firearms to Easy Bound Book.
- You will come back and record the line number from Easy Bound Book in your Disposition notes.
- Do an Acquisition for each firearm you have on-hand into your new book (Easy Bound Book).
- This includes all firearms in your possession whether in your inventory, in for repair or customer returns.
- Do not include firearms that you have sent out for repair or demonstration or any other firearm not in your possession.
- The Acquisition will be from your old bound book.
- Record the line number of the entry from the old book in your notes.
- Use the line number from Easy Bound Book in the notes of the Disposition in your old bound book.
- You must keep your original book(s) because they are your legally required original ATF records.
One last thought. Many clients ask to keep all their records (both open and disposed of) in Easy Bound Book to simplify searches. That is not a problem for Easy Bound Book, but it does require a variance, per the people mentioned in the first paragraph. You may want to keep the records separate, especially if your old book is less than perfect. That way, you can have a clean new book, even though your old book is not perfect.
We can help you automate the process so that it does not take such a long time to do it.