View Full Version : Not renewing my C&R ?

07-31-2005, 5:20 PM
I have desided to not renew my C&R.
My question is, if I deside to sell one of the Rifles I purchased with my C&R after it is no longer active do I still log it into the Bound Book since I am required to keep it for the next 20 years.
I called BATF and the lady I talked to was as confused as I am.
Also I have an SKS that was purchsed before I got my C&R, should that be logged into my Book.

07-31-2005, 7:45 PM
No & no; you may, but it's not required.

Non-licensees are not required to have a bound book.


imported_EOD Guy
08-01-2005, 5:07 AM
There is no requirement for a C&R FFL holder to keep their bound book after they are no longer licensed.

I wrote to BATF Hq in DC and asked about that very subject and that was the reply I received.

08-01-2005, 9:30 AM
Yes, the 20 year rule is for commercial FFLs. They are also required to send their docs in to the BATFE if they go out of business, while C&R holders are not. Once the 03FFL lapses, you can destroy all documents.

Some more paranoid/cautious 03FFL holders in the past intentionally let their FFL lapse every 3 years, destroyed their documents, then got a new one. Dunno if this would be as easy now, since they're paying more attention to 03FFL applications these days.


08-01-2005, 6:30 PM
Once the 03FFL lapses, you can destroy all documents.

Is there somewhere in the regs that I can find regarding this.
So far the only thing I have found says keep them for 20 yrs, but it does not address once you have not renewed your C&R.

Mssr. Eleganté
08-01-2005, 7:29 PM
Is there somewhere in the regs that I can find regarding this

Unfortunatley not. The regs aren't very clear about what Licensed Collectors must do with their bound books after giving up the license.

I always understood the law to say that we had to hold onto the records for 20 years, even after giving up the license. That's because the law says "the records prepared by licensed collectors" need to be retained for 20 years. I figured that even though I may no longer be a licensed collector, my records still had been prepared by a licensed collector.

But EOD Guy got a letter back from BATFE that says we do not have to retain the bound book after giving up the license. I guess they figure that since you are no longer licensed under the law, then they have no way to require you to retain the old records.

I'm holding on to my bound book for 20 years anyway, just in case BATFE changes their interpretation of the law, which they seem to do a lot. But as others have already said, even if you keep the bound book after giving up the license, you do not have to record anymore dispositions. The law says the records need to be "retained" for 20 years, not "maintained". And only current licensees are required to log dispositons.

08-01-2005, 8:09 PM
Thanks Guy's:
I will probably hold onto the Book.
My main concern was if I sold one of my C&R firearms after I quit my License.