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moab
12-21-2009, 6:36 AM
I have an ATF inspection coming up. I received 01 and 08 a year ago. But thru a series of errors CA DOJ has not finalized yet. So I have done nothing with my federal licenses.

I did buy two receivers and a rifle thru another 01 holder. All three for personal use. Do those have to be entered in my bound book?

I have personal firearms from before acquiring the 01. Do those have to be entered into my bound book?

I am storing firearms for my sister in law. Her husband is deceased. Had been LEO. She just didn't want them in her house. Do those have to be entered into my book?

Lastly, does anyone know if either inventory software Gunsafe or Guncollection has been approved by local ATF for replacement of the bound book? Do you have to have your own letter of approval? Or is the first letter published and used by everyone? Like a build approval.

My apologies I had planned to research more fully once our licenses were all approved. And prior to any transactions. I did not expect an inspection prior to CA DOJ finalization.

Thanks for any help. Where is the best place to buy the hard bound books?

Patrick

freakshow10mm
12-21-2009, 7:35 AM
I have an ATF inspection coming up. I received 01 and 08 a year ago. But thru a series of errors CA DOJ has not finalized yet. So I have done nothing with my federal licenses.

I did buy two receivers and a rifle thru another 01 holder. All three for personal use. Do those have to be entered in my bound book?
Did you fill out a 4473 for them? If yes, then no. If you bought them from a dealer using your FFL, it must be entered in your bound book.

I have personal firearms from before acquiring the 01. Do those have to be entered into my bound book?
No.

I am storing firearms for my sister in law. Her husband is deceased. Had been LEO. She just didn't want them in her house. Do those have to be entered into my book?
Are you personally storing them or are you, as an FFL, storing them overnight or longer?

Lastly, does anyone know if either inventory software Gunsafe or Guncollection has been approved by local ATF for replacement of the bound book? Do you have to have your own letter of approval? Or is the first letter published and used by everyone? Like a build approval.
Yes there is software out there. You will need to write and request for a variance to use an electronic bound book. It's pretty in depth as to what specific features need to be met.

My apologies I had planned to research more fully once our licenses were all approved. And prior to any transactions. I did not expect an inspection prior to CA DOJ finalization.
Is this the initial compliance inspection?

Thanks for any help. Where is the best place to buy the hard bound books?
Brownells(.com) has bound books. Make sure they comply with the record keeping requirements. Some they have don't.

moab
12-21-2009, 8:12 AM
"Are you personally storing them or are you, as an FFL, storing them overnight or longer?"

I have had them since he died a couple years ago. It is just for personal reasons. But I would gladly get them out of here if it was a problem.


"Yes there is software out there. You will need to write and request for a variance to use an electronic bound book. It's pretty in depth as to what specific features need to be met."

There are only a few options. To bad they don't just publish a list.


"Is this the initial compliance inspection?"

No. I had that a year and a half ago or so. I think based on what I'm hearing that if I tell her I have no transaction she may just waive it off.

tenpercentfirearms
12-21-2009, 8:46 AM
I have an ATF inspection coming up. I received 01 and 08 a year ago. But thru a series of errors CA DOJ has not finalized yet. So I have done nothing with my federal licenses.

I did buy two receivers and a rifle thru another 01 holder. All three for personal use. Do those have to be entered in my bound book?If that dealer did not DROS them to you, then you used your license to acquire them. Your bound book entry is simple. You input them like you are supposed to and then as long as you are not a corporation, your sign out should have the date, your name, and in the final column "For owner's personal collection".

I have personal firearms from before acquiring the 01. Do those have to be entered into my bound book?No. However, do you keep the personal firearms in the same storage area as the business firearms? If you do, you need to have them clearly labeled "not for sale". I would recommend storing them in another part of the house where you can clearly show an inspector that those are personal firearms and these over here are company firearms. The BATFE recommends you use the "personal firearms record" for clearly tracking what is yours and what is the business's.

I am storing firearms for my sister in law. Her husband is deceased. Had been LEO. She just didn't want them in her house. Do those have to be entered into my book?It sounds to me like these are personal guns. Keep them in your personal area. It might actually be legal for you to store someone else's firearms as long as you make it clear that you are not using them and they fully belong to the sister-in-law. Again, those firearms should be stored separate from the business firearms.

Lastly, does anyone know if either inventory software Gunsafe or Guncollection has been approved by local ATF for replacement of the bound book? Do you have to have your own letter of approval? Or is the first letter published and used by everyone? Like a build approval.Per my warning conference from last month, you no longer need variance approval from the BATFE as long as your software meets their guidelines. I will attempt to get a link or scan my copy of the guidelines later today for you.

My apologies I had planned to research more fully once our licenses were all approved. And prior to any transactions. I did not expect an inspection prior to CA DOJ finalization.

Thanks for any help. Where is the best place to buy the hard bound books?

PatrickI have a Microsoft Excel spreadsheet that exactly mirrors the BATFE example and has now gone through an inspection with zero complaints. The Excel spreadsheet does not meet the requirements of the variance, however, what you can do is keep the Excel spreadsheet and print out the sheets as you use them. You could always go back and reprint sheets if you needed to and it makes finding guns very easy later on down the line. Please e-mail me for a sanitized copy of mine. ad@tenpercentfirearms.com

There is no need to spend money on a bound book when you can just print the sheets out as you go. Plus typing out the entries is much easier. I have someone type out the dispositions too, but we hand write those in and only re-print the page if we have to. So I have a mix of typed and hand written dispositions, but all entries are typed.

ugimports
12-22-2009, 1:12 AM
I have an ATF inspection coming up. I received 01 and 08 a year ago. But thru a series of errors CA DOJ has not finalized yet. So I have done nothing with my federal licenses.
...


I haven't had my inspection yet, but how did you know yours was coming up? I thought they were random and they just showed up. Did you receive advance notification?

moab
12-22-2009, 6:51 AM
I haven't had my inspection yet, but how did you know yours was coming up? I thought they were random and they just showed up. Did you receive advance notification?


She just showed up. But I was sick in bed and asleep. My wife explained. The agent asked a few questions. And left her number on a card. I honestly think she just didn't want to get sick. Everyone else was sick too. I called her back. Apologized for being sick. And explained that I was going to my gastroenterologist so I couldn't meet until the following day. She said she would call back after the New Year. LOL!

That and I had not done anything with my FFL as I had not been approved by the state yet. So there wasn't much to inspect. I also incorrrectly told her that I had made one purchase. Which in retrospect I think she took to mean with my own FFL. It was a personal purchase thru another FFL. Based on what she told my wife. I think once she hears that I have made no transactions. She will probably not come out.

This thread has been very helpful. I was worried that I had been in violation all year by not having all my firearms in a bound book. Good to know it's none of their business.

Am I correct in that assumption? Can they ask to see my personal firearms? And am I obligated to show them?

tenpercentfirearms
12-22-2009, 8:32 AM
Am I correct in that assumption? Can they ask to see my personal firearms? And am I obligated to show them?

Well you can always refuse to consent to anything. The odds of the auditor taking you down at gun point, cuffing you, and then searching the house are slim. However, they can make your life difficult if you make their life difficult.

If you have the personal firearms record already filled out and handy, you can state that you have some personal firearms and here is their information. If she asks to see them you can always state they are in another part of the house and you would rather not. State it is nothing personal and you mean no disrespect and you are just trying to exercise your 4th amendment right to privacy.

I changed my hours after we opened so my auditor showed up on a Monday while we were closed. That gave me Monday night to get some things squared away before they came back Tuesday.

So now I am changing my hours to be open Monday and closed Tuesdays. ;)

moab
12-22-2009, 9:07 AM
"If you have the personal firearms record already filled out and handy..."

Is this a requirement of the FFL license? That you keep a separate record of your personal firearms? I mean the ones that have not passed thru your FFL.

I guess my other question should have been can they "legally" demand to see your personal firearms? And do you "legally" have to show them? Not that I would get into an argument with my local ATF agent. Just curious.

tenpercentfirearms
12-22-2009, 10:41 PM
"If you have the personal firearms record already filled out and handy..."

Is this a requirement of the FFL license? That you keep a separate record of your personal firearms? I mean the ones that have not passed thru your FFL.

I guess my other question should have been can they "legally" demand to see your personal firearms? And do you "legally" have to show them? Not that I would get into an argument with my local ATF agent. Just curious.

I don't have an updated personal record, but I have a corporation at one address and my home at another address.

Again, you can always refuse consent and not show them your firearms. If they have a right to look at them, they will let you know, sooner or later.

I meant to send this discussion to my agent and ask her. I will try to do that and get your A&D copy to you tomorrow.

freakshow10mm
12-26-2009, 12:19 PM
Per my warning conference from last month, you no longer need variance approval from the BATFE as long as your software meets their guidelines. I will attempt to get a link or scan my copy of the guidelines later today for you.

Interesting. My office told me a variance is required and there is no exception to it.

jksupplyco
12-26-2009, 1:52 PM
http://www.atf.gov/regulations-rulings/rulings/atf-rulings/atf-ruling-2008-2.pdf

tenpercentfirearms
12-27-2009, 9:50 PM
Interesting. My office told me a variance is required and there is no exception to it.

From JK's link.

Held further, licensees who wish to use computers to create and maintain their
acquisition and disposition firearms records in accordance with the requirements set forth
in this ruling are not required to obtain advance approval in accordance with 27 CFR
478.22.

freakshow10mm
12-28-2009, 7:11 AM
One hand does not know what the other does.

Thanks guys. Now to search for compliant software....

moab
12-28-2009, 11:18 PM
Does anyone know if Gunsafe meets the requirements? Heard nothing but good things about this one.

http://www.somanyroads.org/gunsafe/