Why is the accuracy of my firearms logbooks so important?
27 CFR § 478.125 details the regulations pertinent to the format and information that’s required in your acquisition and disposition book (A&D). FFLs are required by regulation to keep gun logbooks indicating certain information necessary for tracing firearms found at crime scenes, or otherwise recovered by law enforcement. Your FFL log book is a critical element of your overall compliance requirements.
ATF will focus on your A&D record.
ATF Investigators performing compliance inspections on your firearms business will be examining your firearms acquisition and disposition record book for compliance with regulations. It’s extremely important that you’re in compliance with the record keeping requirements of the Gun Control Act (GCA). ATF considers record-keeping violations a matter of public safety, and ATF investigators are very good at finding errors in your gun logbooks. The ability to trace firearms that have passed through your business is an important law enforcement function. Therefore, ATF takes their examination of the accuracy of your records very seriously during their examinations.
What does ATF specifically look for in their examination of my gun logbooks?
ATF officers will be looking for correct format and accuracy of the information in the record. Although ATF has established inspection protocol, every ATF officer will have a different method of approaching the way in which they check for accuracy of your records. Depending on the initial impression, an ATF Industry Operations Investigator (IOI) may look deeper into your record detail if there are indications of significant problems with the accuracy of your records or internal controls.
Format and Accuracy: 27 CFR § 478.125(e)
Are my gun logbooks in proper format?
Ensure that your A&D record is in the proper format for the entry of information required in the above regulation. The Federal Firearms Regulation Guide (2005 latest as of this writing) contains images of the exact format ATF requires. The format requirement will vary depending on the Type of FFL, and the method in which the firearm was acquired. Ensure that you examine the regulation and implement the correct format for your particular requirements.
Are the entries in my gun logbooks accurate?
FFLs are required to make entries in their A&D record in accordance with 27 CFR § 478.125(e). Failure to make accurate entries is considered a public safety violation. It’s critical that your records are accurate to the best of your ability. See Avoiding Public Safety Violations for tips on maintaining accurate records.
What methods do ATF investigators use to check for accuracy in my gun log books?
ATF officers will use different methods to determine the accuracy of records. Depending on the IOI and your inspection history the examination will take different forms. The following are common methods the IOI may use to check the accuracy of your ATF logbook. The methods will vary depending on the type of license you have and the type of records required.
The IOI may compare the firearms identifiers indicated in the record to your actual inventory. It’s important that you make entries in your firearms log book accurately. This includes the make/model and importer if required. Also ensure that complete and accurate information is entered as required on who you received the firearm from and who the firearms are disposed to. Any required entry is subject to examination for accuracy. This becomes more relevant depending on your compliance history. If you have a history of compliance failures in the accuracy of your A&D record, it may prompt the investigator to scrutinize your record extensively in order to ensure you have corrected the deficiencies.
Cross referencing with the ATF Form 4473
Compare entries on the ATF Forms 4473 on file with entries in your FFL logbook.
The IOI may ensure that dispositions to non-licensees are accurately reflected in the logbook. The IOI will ensure that serial numbers, names and dates match on both documents. Any errors on the records may be cited as a violation of the corresponding regulation. Depending on compliance history and the initial impression, the IOI may either expand the breadth of the examination, or limit it.
Firearms Importers: Your specific Type of license will require specific examination methods.
For importers, ATF may compare serial numbers and other identifiers documented on the ATF forms 6 and 6a to entries in the A&D record, and ensure entries are made timely. Licensed Importers have 15 days from the date of importation, to enter into the record of acquisition and disposition, the information called for in 27 CFR § 478.122.
Electronic A&D records:
Electronic records are authorized under the Gun Control Act (GCA). ATF has provided specific guidance for FFLs who wish to keep records of acquisition and disposition of firearms in electronic form. The requirements of this method are essentially equal to those of 27 CFR § 478.125(e). However, there are certain important elements of electronic record keeping that ATF IOIs will look for during an inspection. Keeping electronic records is a great convenience in many respects, but also opens a door to potential violations and problems if not managed correctly. See the article on ATF electronic firearms record keeping.
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