As a business owner in the firearms industry, you have some special demands imposed on you that may not be required in other fields. You have to keep up with all FFL requirements as a condition of continuing to be licensed. ATF inspections are performed to ensure that records are being kept correctly. With the right record-keeping tools, you can ensure that your business is in compliance. You’ll also find ATF compliance inspections less stressful when you know you’ve filled out the required ATF forms correctly, lower the instance of errors, and lower the number of (incorrect) lost or stolen firearms reported for your business.
Federal Firearms Licensees Requirements
When the ATF released its 2018 FFL Theft/Lost Report, the results were interesting, to say the least. These figures reflected losses and thefts that occurred during the period from January 1, 2018-December 31, 2018 but don’t include firearms reported as lost, but rather categorized this way in error.
- A total of 16,256 firearms were reported lost or stolen from Federal Firearms Licensees (FFLs) nationwide. This number represents a 12 percent reduction from 2016 statistics, when 18,394 firearms were reported stolen.
- Pistols were the type of weapon most likely to be reported lost or stolen (7,842), followed by rifles (3,733), shotguns (1,579), and revolvers (1,574).
- The state reporting the highest number of theft/loss reports was Texas, with 207, followed by Florida with 159, and Georgia with 110.
- Washington, DC; Puerto Rico; and Guam reported no thefts or losses in 2018.
Facility security continues to be of utmost importance, even with these encouraging figures. Part of the ATF’s stated mission is to protect the public from violent crime involving the use of firearms, including those stolen from FFLs.
Just over one-half (54 percent) of the numbers refer to lost firearms for 2018. These 8,814 firearms were put into inventory by an FFL and then could not be accounted for at a later time. Some of the discrepancies may be due to inventory errors; however, improved inventory tracking can greatly reduce these types of issues.
Keeping track of where your firearms inventory is means you will be prepared for ATF inspections when they occur. As a federal firearms licensee, you can expect that you will get audited by the ATF to ensure that you’re in compliance with the Gun Control Act and related laws.
To make this process run more smoothly, you can integrate your inventory software with electronic bound book software. The result is a streamlined, accurate process that will keep accurate records. You don’t have to deal with lost pages, having to decipher illegible handwriting, or wondering whether an entry was duplicated in error. Easy Bound BookTM can be integrated with Microsoft Dynamics NAV or Microsoft Dynamics 365 Business Central for a complete inventory, accounting and A&D bound book package. Contact us today by calling our toll-free number (1-877-571-8580) or filling out our online form.
Common Issues Found at ATF Compliance Inspections
No one wants their ATF inspection to result in a finding that they have one or more issues. The following are some of the most common compliance violations found during inspections.
Violation 1: Failure to Record Entries in the Bound Record (Acquisition and Disposition Book) in a Timely Manner
This issue usually comes down to a misunderstanding of the requirements for recording firearms being purchased and then sold to customers. You may not be entirely clear on the applicable laws or you may have recorded the date incorrectly in your records. If you’re focused on working in your business day to day, your paperwork may have gotten away from you or your employees may not have been paying attention to detail in the way they should.
When it comes to keeping your Acquisition and Disposition Book (A&D Book), the details are important. When you choose an automated A&D bound book for your business, you greatly lower the risk of errors and increase the likelihood that you and your staff will be able to follow the required processes correctly.
Violation 2: ATF Forms that are Incomplete or Contain Errors
In most instances, mistakes will be found during ATF inspections in the A&D Bound Book, ATF Form 4473 (Firearms Transaction Record) and ATF Form 3310.4 (Report of Multiple Sale …). These can be simple oversights, such as the customer purchasing a firearm neglecting to include his middle name or indicating “NMN” (No Middle Name) as instructed on Form 4473. These errors may also occur because you or your employees aren’t fully aware of the legal requirements you must fulfill.
Everyone on your team needs to be aware of the applicable laws when dealing with firearms. You also need to be diligent in filling out and keeping your ATF records up to date. Putting a process in place to record and keep the A&D Book means you will be in compliance with the law and greatly reduce the risk of your next ATF compliance inspection revealing any violations. Easy 4473TM can help reduce your risk in reviewing 4473s.
FFL Requirements When a Firearm is Lost or Stolen
When a firearm is lost or stolen, there are special FFL requirements that must be performed. Within 48 hours of discovering the theft or loss, you must notify the ATF by phone (Toll-free at 1-888-930-9275) or by submitting Form 3310.11 (Federal Firearms Licensee Firearms Inventory Theft/Lost Report) by fax or e-mail (instructions on the form). The ATF’s stated service standard is that it will respond to phone messages and e-mails within one business day. If you have more than one incident of theft or loss to report, a separate form must be used for each one.
Keep track of the date you made your report to the ATF and an Incident Number for the theft or loss will be assigned. The number must be recorded in your A&D Book and on Form 3310.11. The theft or loss is to be recorded as a disposition, as required by 27 CFR Part 178 Subpart H. To fully account for this entry, be sure to include whether the disposition is the result of a theft or a loss, the Incident Number from the police report, and the ATF Incident Number.
To keep track of lost or stolen firearms, add a designation for them in your A&D Book. By creating a “customer” with the name “Lost” or “Stolen” plus your name, your business address and FFL (since ultimately you will be disposing of the firearm to yourself), you can perform a search in your software for all records quickly and easily when needed during an ATF compliance inspection.
Add the ATF Incident Number to the User Note field to keep track of this valuable information. (Be sure to add the words “ATF Incident No. or #” in front of the figures.) This is another way to bring up this valuable information if you prefer to search for the records in this manner.
FFL Requirements When a Firearm is Recovered
If you have previously reported firearms lost or stolen that you subsequently find or recover, record it as an acquisition in your A&D Book. Contact the ATF by phone (1-888–930–9275) to report the recovery.
There is no margin for error in keeping track of your firearm inventory if your goal is to be in continual compliance with FFL regulations. Call us at 1-877-571-8580 or complete our online form today to learn more about Easy Bound Book and which version is right for your business.