Records Required — Licensees

  1. What is a “bound book?”
  2. May a dealer keep more than one “bound book” at the same time?
  3. Does the Government sell a record book for licensees to use in recording their receipts and dispositions of firearms?
  4. What is the dealer’s responsibility where a variance from normal regulatory practice has been authorized?
  5. How much time does a dealer have to record acquisitions and dispositions of firearms in his or her “bound book?”
  6. Are the ammunition record-keeping requirements the same as for firearms?
  7. Are rental firearms subject to record-keeping control?
  8. May a licensee who has firearms in his or her private collection sell any of these firearms without making firearms record entries?
  9. May a licensee maintain computer records in lieu of the “bound book?”
Q: What is a “bound book?”

A “bound book” is a permanently bound book or an orderly arrangement of loose-leaf pages which must be maintained on the business premises. The format must follow that prescribed in the regulations, and the pages must be numbered consecutively.

[27 CFR 478.121 and 478.125]

Q: May a dealer keep more than one “bound book” at the same time?

Yes. A dealer in firearms is not limited to using only one “bound book.” It may be convenient for a dealer to account for different brands or types of firearms in separate “bound books.”

Q: Does the Government sell a record book for licensees to use in recording their receipts and dispositions of firearms?

No. Certain trade associations have them available at nominal cost. Your supplier should be able to tell you about this.

Q: What is the dealer’s responsibility where a variance from normal regulatory practice has been authorized?

The ATF letter authorizing the variance must be kept at the licensed premises and available for inspection. For businesses with more than a single licensed outlet, each outlet covered by the variance must have a copy of the letter authorizing the change.

[27 CFR 478.22 and 478.125(h)]

Q: How much time does a dealer have to record acquisitions and dispositions of firearms in his or her “bound book?”

Generally, licensees have to enter the acquisition or purchase of a firearm by the close of the next business day after the acquisition or purchase and shall record sales or other dispositions within 7 days.

However, if commercial records containing the required information are available for inspection and are separate from other commercial documents, dealers have 7 days from the time of receipt to record the receipt in the “bound book.”

If a disposition is made before the acquisition has been entered in the “bound book,&rdquo the acquisition entry must be made at the same time as the disposition entry.

[27 CFR 478.125]

Q: Are the ammunition record-keeping requirements the same as for firearms?

No. No records are required for ammunition other than armor piercing ammunition. Disposition records must be kept by licensed manufacturers, importers, and collectors for transactions in armor piercing ammunition.

[27 CFR 178.125]

Q: Are rental firearms subject to record-keeping control?

Yes, if the firearms are taken off the premises of the licensee. However, the record-keeping is not imposed on the loan or rental of firearms for use only on the premises of the licensee.

[27 CFR 478.97]

Q: May a licensee who has firearms in his or her private collection sell any of these firearms without making firearms record entries?

A licensee may sell a firearm from his or her personal collection, subject only to the restrictions on firearm sales by unlicensed persons, provided the firearm was entered in the licensee’s bound book and then transferred to the licensee’s private collection at least 1 year prior to the sale. When the personal firearm is sold, the sale must be recorded in a “bound book” for dispositions of personal firearms, but no ATF Form 4473 is required.

[27 CFR 478.125a]

Q: May a licensee maintain computer records in lieu of the “bound book?”

Yes. The Director of Industry Operations or other designated ATF official must approve a request for a record-keeping variance before the licensee may use a computer system in lieu of the “bound book” record required by the regulations.

[27 CFR 478.22 and 478.125(h)]