In the July ATF newsletter, the requirements to keep firearms records electronically—otherwise referred to as electronic bound book regulations—took up half the newsletter. While there were no new announcements, this was a nice summary of the initial regulations and subsequent changes/additions. There were several points that we wanted to point out as reminders for our clients:
- The electronic system cannot be a combination of paper and electronic records. The electronic system cannot rely upon invoices or other paper/manual systems to provide any of the required information. For example, if a licensee chooses to use an electronic record keeping system for any of its required acquisition and disposition records, then all acquisition and disposition records, regardless of type (e.g., gunsmithing, sales, NFA), must also be in the electronic format.
- When a licensed manufacturer changes the model, type, caliber, size and/or gauge of a frame, receiver, or assembly of a firearm, the firearm should remain logged into the A & D record until the changes and/or conversions are complete. Once the change and/or conversion is complete, the licensed manufacturer should log the firearm out of the A & D record as a disposition to itself using the licensed name and licensed number. The date of the disposition is the date of the change/conversion. Concurrently, the licensed manufacturer would record on a separate line the acquisition of the changed/converted firearm as an acquisition from itself on the same date as the date the change/conversion occurred.
All FFLs should reference a full version of ATF Ruling 2016-1, available at: https://www.atf.gov/firearms/docs/ruling/2016-1-requirements-keep-firearms-records-electronically/download