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Colonel Monk
03-08-2012, 4:59 PM
As the FFL holder is not always the one that fills out the paperwork, I'd imagine in some of your shops that you've got an agent dealing with the paperwork, and so I'm curious if it's OK for the FFL's agent (me) to use a signature stamp bearing the owner's (FFL's) signature?

Thanks,

CM

Santa Cruz Armory
03-08-2012, 5:18 PM
Why would you want to do that? Just sign the DROS and 4473 yourself.

Any employee that's not prohibited can release rifles. For pistols, the safe hand gun demo must be done by a qualified person though. If you get your HSC instructor cert you can release H/Gs as well. (there are some exemptions to the HSC)

I do have stamps for the shop name and the FFL license #.

Colonel Monk
03-08-2012, 5:46 PM
Why would you want to do that? Just sign the DROS and 4473 yourself.

Any employee that's not prohibited can release rifles. For pistols, the safe hand gun demo must be done by a qualified person though. If you get your HSC instructor cert you can release H/Gs as well. (there are some exemptions to the HSC)

I do have stamps for the shop name and the FFL license #.

Thanks. I guess since I just started, we had not gotten to that discussion yet. I guess you're saying that as an authorized agent the dealer, I can sign the forms myself, except for the HSC and the Safe Handling Affadavit - True?

Thanks for you help.

CM

kemasa
03-08-2012, 6:23 PM
The first issue with the stamp is that it is not really the person who is claiming to sign it if another uses the stamp. I don't think that the BATF would accept the stamp nor would the FFL really want others to go stamping the name as if it was really the FFL who was claiming to sign it. I think you can get away with it on the FFL that you send out, but that is about it.

The salesperson can sign part of the Safe Handling Affadavit, where is says salesperson, but the HSC instructor has to sign it under their area. Only the HSC instructor can sign the card.

tenpercentfirearms
03-08-2012, 7:20 PM
For the 4473 and the DROS, anyone can sign it.

Only the HSC requires the person with the HSC instructor card to sign it, which all of my staff have and they sign their own.

I always feel weird signing my own 4473 and DROS for my personal firearms, but it is legit.

Colonel Monk
03-08-2012, 9:50 PM
Thanks, gentlemen.

Good to know. I probably will get the HSC before too long for this exact reason.

One other fine point - I'm not a W2 employee at this point, I'm a "consultant" billing an hourly rate, until we decide how our business relationship will continue.....

But I am an agent of the dealer, handling the dealer's business.

I only point this out, to ask if there are any ATF or DOJ requirements for proof of an agent's relationship...

So let me know if there's anything you're aware of please.

Thanks,

CM

tenpercentfirearms
03-09-2012, 7:32 AM
Thanks, gentlemen.

Good to know. I probably will get the HSC before too long for this exact reason.

One other fine point - I'm not a W2 employee at this point, I'm a "consultant" billing an hourly rate, until we decide how our business relationship will continue.....

But I am an agent of the dealer, handling the dealer's business.

I only point this out, to ask if there are any ATF or DOJ requirements for proof of an agent's relationship...

So let me know if there's anything you're aware of please.

Thanks,

CM

For NFA item purposes, you must be an actual employee. So if that is the case, you might need to be an actual employee to sign the papers. In the end, will anyone really care? Probably not as long as everything is in order and as long as the owner understands it is his rear if you are screwing up all of the paperwork.