I agree - This is only 3 months. That is not too long to wait. If you are such close friends, you can loan the girlfriend one of your personal guns (providing she has a valid HSC). It is HER job to make sure he does not have access to it until he is clear.
DOJ may be baiting you. After you called them I would bet anything you have a "surprise" audit in the next few months. Be prepared, have everything in order and above reproach.
The one thing worse than defeat is surrender.