When a customer purchases a firearm from a Federal Firearm Licensee (FFL), the firearm must be “transferred” to the customer using a federal form provided by the ATF called the “Firearm Transaction Record” or ATF Form 4473.
If you’ve ever purchased a firearm from a gun dealer, the 4473 is the form you filled out and signed prior to being able to leave with the gun. And, if you’ve already got your FFL (even from your own home), then you are surely aware of the 4473 and how important it is to have it filled out, and stored, correctly.
In fact, 7 out of the top 10 violations that FFLs across the country receive from the ATF involve the 4473 – it is vitally important!
So, how does an FFL ensure that their 4473 forms are accurately completed and properly stored?
We’re going to cover that in this article.
Summary: Digital storage of your electronic 4473s is the future and comes with MANY benefits. If you’re interested, you need to check out our friends at 4473Cloud.
Accurate 4473 Information
The best method to confirming the information on the Firearm Transaction Record is to properly train your employees to identify and prevent errors AND make it a regular practice to double-check every 4473 before the customer leaves the store.
Employee training is crucial. After all, your employees (even if it’s really just you) are the ones that are going to be standing in front of the customer, filling out the form with them, confirming the 4473 is accurate, and transferring the firearm.
In our ATF Compliance Course for employees, we offer an hour-long course that we hope all new employees are sat down to take on their first day. It covers ATF Compliance basics and a 20-question 4473 quiz that teaches them to spot the most common errors I’ve seen as a firearms attorney representing hundreds of FFLs across the country. (I’ll admit that a couple of the questions stump me, as I swear the form looks good while I keep looking it over, until l find the one mistake that could get you into trouble with the ATF).
Double-Checking Form 4473s
You should ALWAYS have someone other than the person who filled out the Form 4473 double-check your work.
Ideally, this is done before the customer leaves the store as only they can correct their section/information on the form.
Set up whatever system or process you need to ensure this is done and consider a reward program for finding errors. This is not to shame the first employee but rather a motivation to celebrate fixing problems – and, of course, problems can only be fixed after they are found.
Proper 4473 Storage
After confirming that the 4473s are accurately completed, you now have to store them properly.
Yes, improper storage of a Form 4473 can lead to a violation of the Gun Control Act of 1968 (GCA).
As we cover in our courses, you must keep 4473s in the proper order (there are two methods to do this) and also keep them for 20 years (or until you get rid of your FFL, at which point they must be returned to the ATF).
I don’t have to tell you that it can be a pain to keep paperwork in order, especially after many years. And worse, if you need to go back and find a record to confirm information, it can be very time-consuming.
Because of this, I think that using an electronic 4473 is a good idea for many FFLs.
Digital is the future. Like it or not.
Using an electronic 4473 is a great way to reduce errors during transfers because many solutions have some built-in error checks. And, without having to deal with bad handwriting issues, the information is much cleaner.
However, until recently, you had to print out the electronic 4473 and store it as a sheet of paper in your records.
So, although it helped with having more accurate information, it didn’t help with 4473 storage nor information retrieval.
The best solution would be to keep your electronic 4473s, well… electronically.
Digital 4473 Storage
Finally, we have an ATF-approved solution for keeping electronic 4473 on your computer (and backed up in the cloud).
4473Cloud is a new solution from the folks at SilencerShop that works with every electronic 4473 option to keep your electronic 4473s digitally stored and backed up in the cloud.
This not only saves you money from not having to print out your completed forms, it also makes it easier to pass ATF compliance inspections with properly stored records, AND it makes it MUCH easier to search for and find information from past forms.
Additionally, although you might be concerned with electronic storage, it is much more secure and safe!
Now, if you’re worried about security, you really need to go read their site to learn about all the measures they take.
No, the ATF cannot just get to your records, any more than they can by coming in to your store and seeing them in person.
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).