As an attorney specializing in ATF compliance for FFLs, this is a fairly common question I receive. Unfortunately, the simplest answer I have is a common answer from attorneys: “It depends.” The duration for each ATF record that you need to keep as a Federal Firearms Licensee (FFL) depends on which type of FFL License you have and the specific ATF-required record.
When I was the federal government relations manager for the firearm’s industry trade association, the National Shooting Sports Foundation (NSSF), I created a guide for easy reference for FFLs.
We’re going to cover the basics of the ATF’s record-retention requirements for FFLs here, but I’ve included the NSSF guide I created to make it easier for you.
Just click on the image of the guide to view and/or download it for future reference. This is just one example of the great resources the NSSF provides for the industry. If you’re an FFL, you should seriously consider joining the NSSF. They protect our industry like the NRA protects gun owners.
The two most important records for standard dealer FFLs (FFL License Types 1 and 2) are their Acquisition and Disposition (A&D) Records and their Form 4473 transaction records.
As we cover in our online course for getting your own FFL, the ATF is primarily concerned with their ability to trace a gun – these are the main two records that help them!
Record
Retention Time
Dealer’s Acquisition and Disposition Record
20 Years*
Firearms Transaction Record, Form 4473 – Transfers
20 Years*
Firearms Transaction Record, Form 4473 – Background Check without Transfer
5 Years
Multiple Handgun Sales Report, Form 3310.4
5 Years
FFL Theft/Loss Report
5 Years
Manufacturer FFL Records
If you use your manufacturer’s FFL (FFL License Types 7 and 10) to conduct transfers to customers (non-FFLs) via 4473s, then you need to reference the information for dealer FFLs above.
Record
Retention Time
Manufacturer’s Acquisition Record
Forever
Manufacturer’s Disposition Record
20 Years*
Importer FFL Records
Record
Retention Time
Importation/Acquisition Record
Forever
Importer’s Disposition Record
20 Years*
Application and Permit to Import, Form 6 & 6A
20 Years*
* Note: For all the records above that need to be kept for 20 years, they can all be legally discarded/destroyed after 20 years has passed. However, the ATF prefers that you maintain these records for the life of your FFL. If you’d like to get rid of them after 20 years, you can turn them in to the ATF at the same location where you must send your records after you decide to stop being an FFL, the ATF’s Out of Business Records Center.
If you’d like to get your FFL, make sure and check out our online course for getting your own FFL.
If you already have your FFL, and you’d like to learn more about record retention, we cover all the requirements in more detail in our ATF Compliance course.
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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7 thoughts on “How Long do FFLs Need to Keep Their Records?”
Hi Ryan, from your experience can someone get an FFL, open a web site, and make sales Without transferring the actual firearms? Valid license but fraudulent sales? I have what appears to be a valid organization and FFL – but no response after payment. Worried…..
I owned and operated the Wilderness Trails Sporting Goods story in Kooskia, ID back in the 1974-75. At that time I had a FFL and Pawnbroker licenses. How may I check to see if my FFL could be reissued, since I do not know what my FFL licenses number was back then. I still do have a copy of my Pawnbroker license, however. Thank you kindly.
There is no process for getting an FFL “reissued.” Instead, you will have to apply for a new/fresh license if you want one. As we cover in our course, you’ll need to reference the earlier FFL even if you don’t have all of the details.
The laws about this are currently changing. This article is for information only and can’t cover every possible scenario. If you’d like guidance here we cover this in our ATF Compliance Course/Program.
Hi Ryan, from your experience can someone get an FFL, open a web site, and make sales Without transferring the actual firearms? Valid license but fraudulent sales? I have what appears to be a valid organization and FFL – but no response after payment. Worried…..
Anything is possible. If you are concerned about firearm theft, you could contact your local police or the local ATF field division.
I owned and operated the Wilderness Trails Sporting Goods story in Kooskia, ID back in the 1974-75. At that time I had a FFL and Pawnbroker licenses. How may I check to see if my FFL could be reissued, since I do not know what my FFL licenses number was back then. I still do have a copy of my Pawnbroker license, however. Thank you kindly.
Jerry in Montana
There is no process for getting an FFL “reissued.” Instead, you will have to apply for a new/fresh license if you want one. As we cover in our course, you’ll need to reference the earlier FFL even if you don’t have all of the details.
What about the littler documents like FSC tests, Ammo purchases, etc. How long do those need to be kept?
If I’m reading the info above correctly, all 4473s and the A&D books or portions of the A&D books that are older than 20 years can be shredded?
The laws about this are currently changing. This article is for information only and can’t cover every possible scenario. If you’d like guidance here we cover this in our ATF Compliance Course/Program.