To receive a variance, you must fill out form 3311. Sep 30, 2019 based out of avon, ct, orchid advisors provides atf and itar compliance services to manufacturing, distribution, and retail ffls. Atfs new shenanigans with electronic acquisition and. Displays and prints reports in bound book format for a specific serial number, customer, andor date range. Traditionally, dealers like yourself collect this information at the sale in an acquisitions and dispositions book or bound book because of their signature spiral binding. Jan 10, 2018 traditionally, dealers like yourself collect this information at the sale in an acquisitions and dispositions book or bound book because of their signature spiral binding. Oct 06, 2017 the left page of the bound book contained the ffls firearm acquisition information and the right page of the ffls bound book records listed firearm disposition information. The firearm dealer is required to record all information from the form 4473 into a bound book, called an acquisition and disposition log. Atf form 4473 firearm transaction record is promulgated by the bureau of alcohol, tobacco, firearms and explosives so that person licensed under 18 u. Our systems also comply with atf ruling 20108 manufacturer requirements and atf ruling 20111 importers requirements. If the software does not comply, an approved variance must be obtained from atf s firearms industry programs division. The electronic acquisition and disposition bound book software must track correcti. The only variance request that you may want to request from the atf is if you want to use the fileoptionseforms4473auto populate customer name and address setting.
Sep 12, 2019 atf may withdraw the variance at any time if the ffl has violated the terms, or if it believes the effective administration of its statutory responsibility is being hindered by the continuation of the variance. Most ffls performing gunsmithing and repairs maintain a separate bound book. The pact act law went into effect on june 29, 2010. This setting is enabled by default in ez arms keeper. As an ffl, you already know that manufacturers and importers must mark firearms with specific information required by atf regulations. Written by jarad haselton updated over a week ago automatic electronic transfers.
May 01, 2018 discussions pertaining retail and manufacturing ffl technology, electronic bound books, electronic 4473s and electronic storage will also be held at this years 2018 firearm industry compliance. However if you send it to an ffl to do the work, there are rules for him to ensure the integrity of the manufacturing markings, and to keep the chain of posession intact by recording the info in his bound book. The solution the solution they chose was easy bound book pro the results basm created a solution to prevent duplication of serial numbers, so that all of morrisseys receivers are uniquely numbered. Will afford security and protection that are substantially equivalent to those prescribed by federal explosives law and regulations. In addition, basm designed a variance management tool to make sure that serial. Ffls take notice manufacturer and importer must be listed. What state abbreviations are acceptable to use in my bound book. Lookbooks for guns is the premier atf compliant electronic log book software system. Bookfactory atf bound book atf log book atf record book 100 pages, blacktranslux cover wireo, 11 x 8 12. Atf has received inquiries from members of the firearms industry seeking to maintain their. It is the book where every single firearm acquisition by the ffl holder is recorded as well as the disposition of every firearm.
Feb 06, 2012 all federal firearms licensees need to take notice that both the manufacturer and the importer must be listed in hisherits bound books, pursuant to 27 c. A catalog of frequentlyasked questions received on our 247 nssf member compliance hotline and the responses given by our atf compliance team. Ffl software for electronic bound book record keeping is flexible enough to. Some may have converted to electronic bound books if issued a variance by the atf, but this is not yet the norm. Atf will generally grant a marking variance in this context. Bookfactory atf bound bookatf log bookatf record book 100 pages, blacktranslux cover wireo, 11 x 8 12. Atf variances not only for marking easing the burden on.
A substantial portion of manufacturers are very familiar with the marking variance. If the manufacturerimporter has obtained a variance to the marking. Meets and exceeds the atf compliance standards atf ruling 20161 for electric bound books and gives you the ability to totally automate the process and focus on your business, not your backups. That means someone has to physically go and paw through their bound book and possibly the 4473 forms at each dealer to prove that a record does not exist. Atf publishes three rulings on recordkeeping part 1 of 3. The atf exercises their flexibility by way of the variance.
Therefore, atf finds that there is good cause to authorize a variance from the requirements of the federal firearms regulations as they relate to completion of the atf form 4473. No more illegible handwriting, duplicate entries or lost pages. The easiest way to request a marking variance is to fill out atf form 3311. We have developed new software to comply with atf new ruling 205 for ffl dealers, manufacturers, and importers. Orchid ebound is an atf 20161 compliant electronic acquisition and disposition book designed by industry professionals for industry professionals.
Easy bound book lite designed for the basics, easy bound book lite is a cloud only solution us based servers, of course. Variance permits first eform 4473 electronic storage. Therefore, atf finds that there is good cause to authorize a variance. Atf would generally grant a variance from the record keeping requirements upon request and only after examination of record keeping software by atf industry operations investigators ioi. May 01, 2018 this variance, specific to grabagun, permits the licensee to retain an electronic copy of an e4473, in lieu of paper, provided that certain conditions are met. Easy bound book meets atf 20161 requirements for electronic recordkeeping and makes atf audits a breeze. Jan 16, 2014 recently, the bureau of alcohol, tobacco, firearms and explosives atf announced atf ruling 205, regarding requirements for implementing and maintaining electronic acquisition and disposition records that federal firearms licensees must keep, without any opportunity for notice and comment, in direct violation of the administrative procedures act apa, and invalidated a number of. Ffls take notice manufacturer and importer must be listed in. The dealer must keep the form 4473 on file for at least 20 years, and is required to surrender the log book to the atf upon retirement from the firearms business. Atf also finds that, provided certain conditions are met, the alternate method set forth in this ruling is consistent with the provisions of 27 cfr 478. Therefore, atf finds that there is good cause to authorize a variance from the firearms acquisition and disposition recordkeeping requirements of the federal firearms regulations. Atf log book compliance matters firearms record book. This form outlines all the required information for a successful marking variance application.
Extensive data security is employed by all gun storemaster software. Requirements to keep firearms records electronically bureau of. Blanket approval for compliant computerized records. Atf s firearms and ammunition technology division fatd is responsible for analyzing and responding to marking variance requests. Yes, 4473s for customer purchases are very important too most violations of the law come from these. While many ffls just list the manufacturer, especially when the manufacturer and importer are the same or the same company but different corporate structures throughout the. All other records and forms are automated through the retail sales process. Registration, reporting, delivery requirements, recordkeeping, list of unregistered or noncompliant delivery sellers. I dont believe the atf s e4473 exports to anything. Atf finds that there is good cause to authorize a variance from the firearms.
Approved by the atf, the log satisfies the atf requirement that firearm dealers keep a bound book recording their firearm acquisitions and gives enough space for each. We have identified each step with who the point is talking about. Variance permits first eform 4473 electronic storage approval. Written by jarad haselton updated over a week ago free trial. Serial number searches are fast and efficient, and your bound book is legible. These books conveniently include spaces for recording required data on up to 900 firearms lines are numbered from 1 900. Atf bound book, was heading toward the unmanageable. Getting an ffl isnt that hard, but keeping it can be a challenge. If the manufacturerimporter has obtained a variance to the m. The director of industry operations or other designated atf official must approve a request for a recordkeeping variance before the licensee may use a computer system in lieu of the bound book record required by the regulations. Easy bound book is perfectly tooled for morrissey inc. Sep 26, 2020 the atf takes bound book violations very seriously.
May a licensee maintain computer records in lieu of the bound book. Please check with your atf agent to determine if you need to submit a variance for computerized recordkeeping. This record takes the form of a bound book in which entries are written. Request a marking variance for firearms atf home page.
The bureau does not issue blanket approvals for commercially available software programs nor does it endorse any particular product. Or must the ffl log the firearms in his books after doing the nics check and releasing the firearm to the buyer. All requests for a computerized recordkeeping variance must be sent to the director of industry. A licensee may maintain computer records in lieu of the bound book. Optional signature capture capability atf variance required fully integrated with gun storemaster insure your atf bound book matches the 4473. Licensed firearms importers are required to maintain records of acquisition and disposition according to 27 cfr 478. Some of the information you will be required to list is shown below. As a firearm is acquired made or received on the left side, the same line on the right side stayed empty blank until the firearm was disposed sold, transferred.
The firm offers ffl and export licensing, deep record inspections, e4473 nfa eforms, electronic bound book software and delivers the largest online atf and itar compliance training platform available. Why you cant keep firearms acquisition and disposition. Recent advances in technology have increased requests from industry for approval of computerized firearms records. Ricks guns would submit a marking variance request to atf requesting authorization to adopt the identifying information of alz, inc.
It can be easily disabled by unchecking the checkbox. The core records for every ffl are the ffl bound books. With the electronic bound book solution that goal will be achieved. The bureau of alcohol, tobacco, firearms and explosives atf. Atf may withdraw the variance at any time if the ffl has violated the terms, or if it believes the effective administration of its statutory responsibility is being hindered by the continuation of the variance. Compliance with the provisions of the ruling is required for the continued use of a computerized ffl bound book. Remember that ffls keep their records in their bound book per atf regulations. The regulations state that a variance may be issued in lieu of a method or procedure specifically prescribed by regulation. Approved by the atf, the log satisfies the atf requirement that firearm dealers keep a bound book recording their firearm acquisitions and gives enough space for each entry to be logged neatly and correctly, making it easy to read and easy to record. Atf variances not only for marking easing burden on your. Ffls take notice manufacturer and importer must be. E9 may a licensee maintain computer records in lieu of the bound book. Firearms acquisition and disposition record book hardcover.
The marking variance request should be submitted to atf by the initial manufacturer who is manufacturing the receivers and does not desire to place their identifying markings on the receiver. Designed with the specific requirements of firearm dealers, collectors, and buyers in mind, skyhorse publishings firearms acquisition and disposition record book is the perfect log for tracking firearm purchases and sales. Rick gridley, director, public affairs, big 5 sporting goods. The regional director compliance or other designated atf official must approve a request for a recordkeeping variance before the licensee may use a computer system in lieu of the bound book record required by the regulations. Marking variances are necessary when a manufacturer intends to manufacture and mark firearms on the behalf of another manufacturer. Atf seeks to provide the industry with guidance on the requirements for submitting a letter of application to request a marking variance. Other licensees seeking an atf variance of this type must contact atf and follow their variance request process. Durable, easy to use, and perfectly designed to meet the specific. Integrated with orchids e4473 technology, the software allows you to manufacture, distribute and sell gca and nfa firearms to consumers. Excel isnt just a poor solution, its noncompliant with the atf. Atf responded in 2008 by implementing blanket approval for the use of computerized ffl acquisition and disposition books and revised the ruling in december 20. Bookfactory atf disposition of personal firearms record book 120 pages red cover smyth sewn hardbound 8 12 x 11 log1207cslr gundrpf 4. It has been used so often that the atf created a standard form atf form 3311. Automatically enter transactions to the right ffl variance from atf required if.
It is a great option when you just want quality software to keep you compliant with the atf quickly and easily. The ffl bound book is at the heart of a gun business. These professional grade atf bound books are essential for preserving firearm data and proving compliance with atf p 5300. Simple multigun dispositions from a single 4473 form. Our primary objective is to deliver an outstanding retail experience to firearm consumers during every touchpoint without adversely impacting our atf compliance or operating efficiency. Yes, atf form 4473 is critical, too most violations come from 4473 mistakes, but if you think of your ffl like a solar system, your ffl bound books are the sun. The electronic acquisition and disposition bound book software must track corrections. Integrated with ffl bound book firearms for dualregulated items like ddmunitions with serial numbers andor lot codes for atf ruling 20165 using milstd1168c and milstd special features for manufacturers. Product solutions easy bound book flexible ffl software. Getting your ffl isnt too hard but keeping it, now that can be a challenge.
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