It is that time again. The ATF has officially updated the over the counter “Firearms Transaction Record”, more commonly known as the ATF Form 4473.
Like most in the firearm industry, you are probably aware that every 3 years to so, a newly revised version of your favorite ATF form is released. While the past has shown these revisions to be minor in the overall flow of the 4473 itself, this newest version of the 4473 is quite different in appearance from previous versions.
The nature of the latest changes to the new 4473 will impact how you, as an FFL, operate when selling a firearm.
The firearm/s information (formally part of Section D) is now Section A, which must be completed before the transferee completes Section B.
Added a checkbox and “Non-Binary” after female in the gender box.
A new item (26c.) has been included for the recording of official military orders establishing permanent change of station.
The “County” block has been changed to “County/Parish/Borough” to accommodate Louisiana and Alaska, respectively.
For a full list of the updates made to the 4473 click here.
What Does This 4473 Update Mean to You as an FFL?
In addition to making sure that you use the new form 4473, there are a few changes to your daily operation as an FFL because of this new form. There are changes to the timing of the information and also the questions on the 4473 for your customers.
Timing of Information
Let’s start with a typical sales process in most FFLs (BEFORE this update):
Customer selects the firearm they want,
You give them the 4473 (if you still use paper – if you do, there is a compelling case for you to upgrade your operations and start using an electronic 4473 software), or, direct them to complete the 4473 digitally.
You retrieve the firearm (sometimes in the “back” of the store) and enter the firearm’s information after the customer filled out their part of the form.
This is no longer the case!
The firearm information that was previously part of Section D of the 4473, is now Section A and must be completed PRIOR to the customer completing their section of the 4473. Yes, you guessed it, what was Section A (customer information), is now Section B of the newest version of the 4473.
Therefore, with this new 4473, you must START with the firearm’s information before handing the 4473 over to the customer for them to start filling gout their information.
If you’d like a step-by-step explanation of the new 4473, including a quiz that helps you spot and understand errors on the new 4473, you might want to check out our ATF Compliance Program.
Without getting into a deeper discussion regarding gender, regardless of your personal point of view, the 4473 has a new option for your customers. We will keep this as factual as possible. If the state in which your customer resides recognizes a gender beyond male and female, your customer’s may select non-binary on the 4473. To do so, their ID must also show that according to the state this is a valid selection. NOTE – not all states recognize a third/non-binary option for gender, and we encourage you to research the states that do and don’t on your own.
One of the most common errors on a 4473 involved a customer writing their COUNTRY instead of their COUNTY. For example, they’d write “U.S.A.” instead of “Hazzard. This new form aims to help solve this problem by no longer just listing “County” for the question and instead lists “County/Parish/Borough” which should help some folks recognize that they aren’t being asked for their COUNTRY and also it makes make more sense for some states which do not have “counties.”
Steps to Take for the New 4473
As you can see,at these changes will take some time to adjust too. Updating and training your store team is a crucial task to avoid non-compliance once you are required to use the newest version of the 4473. The paper version of the 4473 is available now through the ATF’s distribution center, and many of the e4473 software providers are in the mist of rolling out the new form digitally as well. The newest version of the 4473 can be downloaded here.
Keep in mind the mandatory date in which you as an FFL must use the newest version of the 4473 is November 1, 2020. If you haven’t already done so, we encourage you to reach out to your e4473 software provider to inquire on the release date for their version of the new 4473. Alternatively, if you are still using paper, you may have the new version already and if you don’t can order them immediately through ATF.
There are many, many advantages to using a digital or electronic version of the 4473. Updates and revisions like this are just one example of how software can make your life easier. Most e4473 software companies provide digital guardrails to keep your compliance with completing the 4473 in great shape. Also, many are integrated with an eBound Book and/or with a point of sale system to help streamline your receiving and sales processes.
Complete List of 4473 Changes for 2020
Here’s a list of ATF’s changes to the new 4473 (from their website here):
Deleted first sentence
Changed second sentence from “The information you provide will be used to determine whether you are prohibited from receiving a firearm.” to “The information you provide will be used to determine whether you are prohibited by Federal or State law from receiving a firearm.”
Added “Any person who exports a firearm without proper authorization from the Department of Commerce or the Department of State, as applicable, is subject to a fine of not more than $1,000,000 and up to 20 years imprisonment.”
Created a new Section A by moving Section D, Questions 24-28 Firearm(s) Description to after the warning paragraphs. Renumber as Questions 1-5.
Question 1 (Former Question 24) Manufacturer and Importer:
Removed “the FFL must”
Multiple Purchases of Handguns reminder- Moved to after Questions 34-36.
Question 6 (Former Question 29) Total Number of Firearms Transferred:
Changed to “Total Number of Firearms to be Transferred”
Changed “Please handwrite by printing” to “Please spell total number”
Question 7 (Former Question 30) Pawn Redemption:
Added “Record” before “Line”
Question 8 (Former Question 32) Private Party Transfers:
Relocated to Section A from Section D
Section B (Former Section A)
Question 9 (Former Question 1) Transferee’s/Buyers Full Name:
Changed “recored IO” after the initial” to “record the initial followed by “IO” in quotes”
Question 10 (Former Question 2) Current State of Residence and Address:
Added “/Parish/Borough” after “County”
Question 11 (Former Question 3) Place of Birth:
Bolded “and” between “City” and “State”
Question 14 (Former Question 6) Sex:
Added a check box and “Non-Binary” after female
Question 17 (Former Question 9) Unique Personal Identification Number:
Added “or Appeals Management Database Identification (AMD ID),” after “(UPIN)”
Question 18.b (Former Question 10.b) Race:
Removed “In addition to ethnicity,”
Question 19 (Former Question 12.a) Country of Citizenship:
Relocated for clarity
Question 20 (Former Question 13) U.S.-Issued Alien or Admission number:
Relocated for clarity
Question 21 (Former Question 11) Header:
Changed “by checking or marking “yes” or “no” in the boxes” to “by checking or marking either the “yes” or “no” box”
Question 21.a (Former Question 11.a) Actual Transferee/Buyer:
Added “and any continuation sheet(s) (ATF Form 5300.9A)?” after “firearms listed on this form”
Changed “If you are picking up” to “If you are only picking up”
Question 21.b (Former Question 11.b) Under Indictment:
Added “, or are you a current member of the military who has been charged with violations of the Uniform Code of Military Justice and whose charges have been referred to a General Court-Martial?”
Question 21.c (Former Question 11.c) Felony:
Added “, including a military court,” after “court”
Changed “The person transferring” to “The individual transferring.”
Changed “the person who completed” to “the individual who completed.”
Transferor Certification First sentence
Changed “the information recorded in Sections B and D” to “the information recorded in Sections A, C and E.”
Changed “my licensed business premises” to “the licensed business premises”
Added “by NICS or State Agency” after “cancelled”
Changed “my verification” to “the verification”
Changed “my re-verification” to “the re-verification”
Question 36 Transferor’s/Seller’s Title:
Removed from form
Question 36 (Former Question 37) Date Transferred:
Added blocks for Month/Day/Year
Notices, Instructions, and Definitions
Purpose of the Form – Paragraph 1: Changed “(See ATF Publication 5300.5, State Laws and Published Ordinances.” to (See State Laws and Published Ordinances – Firearms (ATF Electronic Publication 5300.5) on https://www.atf.gov.)
Purpose of the Form – Exportation of Firearms (Paragraph 6): Information moved to warning section on first page
Changed “Firearms manufactured after 1968 by Federal firearms licensees should all be marked” to “All firearms manufactured after 1968 by Federal firearms licensees should be marked”
Changed “If more than four firearms are involved in a transaction, the information required by Section D, questions 24-28, must be provided for the additional firearms on a separate sheet of paper, which must be attached to the ATF Form 4473.” to “If more than three firearms are involved in a transaction, please provide the information required by Section A, Questions 1-5 on ATF Form 5300.9A, Firearms Transaction Record Continuation Sheet. The completed Form 5300.9A must be attached to this Form 4473.”
Changed “and other firearms that are neither” to “and firearms that are neither”
Question 8 (Former Question 32.) Private Party Transfer
Removed “or write “Private Party Transfer in question 31,”
Changed “ATF Procedure 2013-1” to “ATF Procedure 2017-1”
Section B (Former Section A)
Changed “certify (sign)” to “certify (sign and date)”
Question 9 (Former Question 1) Transferee’s/Buyer’s Name
Removed “in question 1”
Question 10 (Former Question 2) Current Residence Address
Removed “County and Parish are one and the same”
Changed “duty station address and his/her residence address” to “duty station address and residence address”
Changed “State X, he/she should list the address” to “State X, list the address”
Removed “in response to question 2” from sentences 2 and 3
Question 14 (Former Question 6) Sex
Added “”Individuals with neither male nor female on their identification document(s) should check Non-binary.”
Question 17 (Former Question 9) Unique Personal Identification Number
Added “The AMD ID is a number that will be provided to an appellant on certain types of overturned appeals and should be recorded in question 17. The transferor/seller should provide the UPIN/AMD ID when conducting background checks through the NICS or the State POC.”
Question 18.a and 18.b (Former Question 10.a and 10.b) Ethnicity and Race
Removed “Pursuant to Office of Management and Budget (OMB), effective January 1, 2003, all Federal agencies requiring collection of race and ethnicity information on administrative forms and records, were required to collect this information in a standard format. (See 62 FR 58782) The standard OMB format consists of two categories for data on ethnicity: Hispanic or Latino,” and “Not Hispanic or Latino” and five categories for data on race: American Indian or Alaska Native, Asian, Black or African American, Native Hawaiian or Other Pacific Islander, and White.”
Changed “Any other race or ethnicity that does not fall within those indicated, please select the closest representation.” To “Select the closest representation for any other race or ethnicity that does not fall within those indicated.”
Question 20 (Former Question 13) U.S.-Issued Alien Number or Admission Number
Changed “If you are a U.S. citizen or U.S. national than this question should be left blank.” to “If you are a U.S. citizen or U.S. national, the response to this question should be left blank.”
Question 21.a (Former Question 11.a) Actual Transferee/Buyer
Removed “ACTUAL TRANSFEREE/BUYER” from before EXAMPLES
Added “(h)” after 18 U.S.C. 922(g)
Removed “EXCEPTION: If a person is picking up a repaired firearm(s) for another person, he/she is not required to answer 21.a and may proceed to question 21.b”
Changed “convicted of a felony in any Federal, State or local court” to “convicted of a felony in any Federal, including a General Court-Martial, State or local court”
Changed “convicted of a misdemeanor crime of domestic violence under Federal, State or Tribal law” to “convicted of a misdemeanor crime of domestic violence under Federal, including a General Court-Martial, State or Tribal law”’
Changed “under indictment or information for a felony in any Federal, State or local court” to “under indictment or information for a felony in any Federal, including a General Court-Martial, State or local court”
Moved “this does not include State misdemeanors punishable by imprisonment for two years or less” to third paragraph, EXCEPTION
Split first sentence into two. “A member of the Armed Forces must answer “yes” to 21.b. if charged with an offense that is referred to a General Court-Martial. A current or former member of the Armed Forces must answer “yes” to 21.c. if convicted under a General Court-Martial.”
Second sentence, removed “from the Armed Forces”
Changed “ A person who has been convicted of a felony, or any other crime, for which the judge could have imprisoned the person for more than one year, or who has been convicted of a misdemeanor crime of domestic violence, is not prohibited from purchasing, receiving, or possessing a firearm if: (1) under the law of the jurisdiction where the conviction occurred, the person has been pardoned, the conviction has been expunged or set aside, or the person has had their civil rights (the right to vote, sit on a jury, and hold public office) taken away and later restored, AND (2) the person is not prohibited by the law of the jurisdiction where the conviction occurred from receiving or possessing firearms. Persons subject to this exception, or who receive relief from disabilities under 18 U.S.C. 925(c), should answer “no” to the applicable question.” to “A person is not prohibited from receiving or possessing a firearm if that person: (1) has been convicted of any Federal or State offense pertaining to antitrust violations, unfair trade practices, restraints of trade, or other similar offenses relating to the regulation of business practices; (2) has been convicted of a State misdemeanor punishable by imprisonment of two years or less; or (3) following conviction of a felony or other crime for which the judge could have imprisoned the person for more than one year, or a misdemeanor crime of domestic violence, has received a pardon, an expungement or set aside of the conviction, or has lost and regained civil rights (the right to vote, sit on a jury, and hold public office) in the jurisdiction in which the conviction occurred, AND the law of the convicting jurisdiction does not prohibit the person from receiving or possessing firearms. Persons subject to any of these exceptions, or who received relief from disabilities under 18 U.S.C. 925(c), should answer “no” to the applicable question.”
Question 21.f. (Former Question 11.f.) Exception
Moved the “or” from in front of “(d)” to in front of “(e)”
Moved “Persons who fall within one of the above exceptions should answer “no” to question 21.f.” to the end of the paragraph.
Question 21.i. (Former Question 11.i.) Misdemeanor Crime of Domestic Violence
Changed “A Federal, State, Local, or tribal offense” to “A Federal, including a General Court-Martial, State, Local, or tribal offense”
Added new paragraph “A current or former member of the military who has been convicted of a violation of the Uniform Code of Military Justice that included, as an element, the use of force against a person as identified in the instructions under question 21.i. must answer “yes” to this question. This may include a qualifying offense that was referred to a Special or General Court-Martial.”
Question 21.l. (Former Question 12.d.) Immigration Status
Second sentence, added “to establish they are excepted from the nonimmigrant alien prohibition”
Added “leave 21.l.2 blank” after “may answer “no” to this question”
Section C (Former Section B)
Question 24. (Former Question 16.) Category of Firearm(s)
Changed “However, frames and receivers are still “firearms” by definition, and subject to the same GCA limitations as any other firearms.” to “All frames and receivers are “firearms” by definition, and subject to the same GCA limitations.”
Added “Identification documents such as a driver’s license or identification card issued with binary, non-binary, or no sex designation may be used as an identification document.” before “A combination of government-issued”
Changed “should list the transferee’s/buyer’s military identification card and official orders showing where his/her permanent duty station is located in response to question 18.a.” to “must list the transferee’s/buyer’s military identification card in response to question 26.a., in addition to PCS orders as indicated in 26.c.”
First sentence, changed “ answers “no”” to “answered “no”” and “answers “yes”” to “answered “yes””
Second sentence, changed “violates the law, even” to “violates the law, 18. U.S.C. 922(d), even”
Third Paragraph moved to second paragraph of NICS Responses and changed to:
At the time that NICS is contacted, the licensee must record in question 27.a. -27.c.: the date of contact, the NICS (or State) transaction number, and the initial response provided by NICS or the State. The licensee may record the date the firearms may be transferred to the transferee/buyer (also known as the Missing Disposition Information (MDI) date) in 27.c. that NICS provides for delayed transactions (States may not provide this date). If the licensee receives any subsequent response(s) before transferring the firearm, the licensee must record in question 27.d. any response later provided by NICS or the State, or that no response was provided within 3 business days. If the licensee receives a response from NICS or the State after the firearm has been transferred, he/she must record this information in question 27.e. If the transaction was denied and later overturned in addition to checking “Proceed” in question 27.d. and entering the date, the licensee must also check “Overturned” and, if provided, attach the overturn certificate issued by NICS or the State POC to this ATF Form 4473. If more than 30 days have elapsed and a new NICS check is required, record the new transaction number, date of contact and the response provided by NICS or the State on this Form 4473 in questions 27.a.-27.c. Note: States acting as points of contact for NICS checks may use terms other than “proceed,” “delayed,” “cancelled,” or “denied.” In such cases, the licensee should check the box that corresponds to the State’s response.
The following was moved to the end of the first paragraph of NICS Responses.
Some States may not provide a transaction number for denials. However, if a firearm is transferred within the three business day period, a transaction number is required.
NICS Response first paragraph
Changed “If NICS provides a “cancelled” or “denied” response” to “If NICS provides a “denied” or “cancelled” (and does not immediately provide a new transaction number)”
Added “or other requirements” after “waiting period”
Section E (Former Section D)
Question 32 (Former Question 31) For Use by Licensee
Added “or any additional information received from NICS that is not recorded in Questions 27.a. – 27.e.”
Overall Form Changes
Removed “See Instructions for Question” from all individual question blocks
Removed “Transferee/Buyer Continue to Next Page” from pages 1, 2 and 3
Ryan Cleckner is a former special operations sniper and current attorney specializing in firearms law/ATF compliance and is a firearms industry executive (former govt. relations manager for NSSF, Vice President of Remington Outdoor Company, and a SAAMI voting board member).
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