Renew COE. Where to Enter FFL-03 Info

[G. Freeman]

Hello Guys,

I'm renewing my COE. But on the CFARS website, there's no place to enter my FFL-03 number. I want to prevent the incomplete notice that I had a headache dealing with last year.

Would you know the place for me to enter this info?

Thanks in advance!

[dfletcher]

My C&R FFL expired shortly before COE renewal. I went to "User Profile" and updated the expiration date then saved. I then sent a separate e-mail with the new FFL number.

IIRC I also uploaded to "Documents" in the drop down box.

[sbo80]

I added a copy of my 03 as an attachment. There's not a "choice" for it, so just pick something else. I think I picked "court documents" or something weird. They didn't write back, they just approved it on the first submission.
Do note that others have the same success, on a similar timeline, waiting for the rejection email and responding back with "it isn't required". Giving them the number doesn't seem to make it go faster, just saves an email.

[beachbaker]

I also just updated my 03 in my profile and renewed without a problem.

[DrewN]

I'm pretty sure they only ask for your 03 if you check "collector". Not 100% sure,mind.

[G. Freeman]

Hi Guys, yeah I uploaded my CDL, and tried to upload a word doc with my FFL info but it would not allow to upload under other documents.

Was I doing something wrong? It seemed the site would only allow 1 document to be uploaded when renewing.

Eventually entered the FFL-3# under user profile. However the expiration is a week after my COE expiration (FFL3 being renewed too).

Did I do okay?

[19K]

Don’t give them your C&R number. It’s none of their business.

Ask them to provide the PC requiring you to give them a C&R FFL 03 number. They will not reply and then process your COE.

Don’t give them anything more than what is required by law. My COE was not delayed, not withheld, not denied. No one’s is when they refuse to give that info.

This is what I and many other send to the DOJ when they ask for the number.

CFARS has notified me that my COE application is incomplete, indicating that I must submit an FFL-03 license to complete processing.

I have never been asked for this information during initial application. Would you please provide me with the reasons and authorities for requiring this information? As my COE expires within 30 days, I would appreciate a response to this request within the next 10 days.

Alternatively, please accept the documentation I have submitted as meeting the stated requirements of statute and regulation and complete processing of my COE.

[sbo80]

Originally Posted by 19K

Don’t give them your C&R number. It’s none of their business.

That's a fine notion, but it doesn't mean much. The number is required on pretty much every other form. The C&R acquisition forms, DROS gets a copy if you are wanting an exemption. So you aren't "protecting" yourself from anything or keeping it a secret. It's not required, sure. And their system sucks as they probably already have it elsewhere. But "they" also have your driver license info and they make you type that in, plus add a copy of it. Every year. Yes they suck.

[19K]

Originally Posted by sbo80

That's a fine notion, but it doesn't mean much. The number is required on pretty much every other form. The C&R acquisition forms, DROS gets a copy if you are wanting an exemption. So you aren't "protecting" yourself from anything or keeping it a secret. It's not required, sure. And their system sucks as they probably already have it elsewhere. But "they" also have your driver license info and they make you type that in, plus add a copy of it. Every year. Yes they suck.

DROS does not get a copy. It’s a federal license. . Dros gets your COE number.

[Dvrjon]

Originally Posted by sbo80

That's a fine notion, but it doesn't mean much. The number is required on pretty much every other form. The C&R acquisition forms, DROS gets a copy if you are wanting an exemption. So you aren't "protecting" yourself from anything or keeping it a secret. It's not required, sure. And their system sucks as they probably already have it elsewhere. But "they" also have your driver license info and they make you type that in, plus add a copy of it. Every year. Yes they suck.

The DROS paperwork doesn't contain your FFL-03 license number.

California Department of Justice
Bureau of Firearms
DES Application – Firearms and Ammunition Dealer User Guide
Page 51/52

Quote:
CURIO/RELIC HANDGUN SALE
Select the Curio/Relic Handgun Sale transaction type when the handgun being purchased meets the Curio/Relic handgun definition.

To submit a Curio/Relic Handgun Sale Transaction:
1) From the Main Menu page, select the Submit DROS link. The Select Transaction Type page will display.
2) Select the Curio/Relic Handgun Sale link. The Submit Curio/Relic Handgun Sale form will display.
3) Enter the Purchaser Information (see Entering Purchaser and Seller Information above).
4) Enter the Transaction and Firearm Information as follows:
a. Gun Show Transaction – Select Yes or No from the drop down list.
b. Waiting Period Exemption – If applicable, select a waiting period exemption:
• CFD Number – Select CFD from the drop down list if the purchaser is an
active licensed firearm dealer. Selecting the CFD number waiting period
exemption displays a Purchaser CFD Number field. Enter the purchaser’s
valid CFD number.
• Collector – This waiting period exemption requires a valid 03 FFL and
COE. Enter the purchaser’s valid COE. You must keep a copy of the 03 FFL and COE on file.

[sbo80]

^thanks for the clarity, I guess I over exaggerated. Seems the FFL keeps a copy of your 03 but doesn't actually send it on to the DOJ. I didn't know that part, just that I've always handed it over.
The other part is still valid. BOF961 (Collector In-State Acquisition) and BOF4100 (C&R Firearm Report) both explicitly require your # on the form. Those of us that do transactions without DROS, already give up our number. If you don't do those and are only using your 03 for ammo purchases and skipping 10-day waits, then I guess you can continue to keep your FFL# a secret from DOJ.

[Dvrjon]

Originally Posted by sbo80

^thanks for the clarity, I guess I over exaggerated. Seems the FFL keeps a copy of your 03 but doesn't actually send it on to the DOJ. I didn't know that part, just that I've always handed it over.
The other part is still valid. BOF961 (Collector In-State Acquisition) and BOF4100 (C&R Firearm Report) both explicitly require your # on the form. Those of us that do transactions without DROS, already give up our number. If you don't do those and are only using your 03 for ammo purchases and skipping 10-day waits, then I guess you can continue to keep your FFL# a secret from DOJ.

Please don't misunderstand the issue here.

It's not about keeping the FFL-03 secret, it's about telling DOJ they've overstepped their authority and you are not going to comply. Every time they've asked for my FFL-03 I've responded with, "Why?", they've issued within days.

Moreover, a few months ago, I bought three pistols working with a Sportsman's manager with whom I'd dealt before. When I went in to pick up the guns, he told me DOJ called and wanted to know how I was able to purchase 3 guns at the same time. He had to explain their process to them.

It's just another example of either willfully looking for opportunities to stop purchases and infringe on rights, or it's gross stupidity due to lack of training...they don't even know where to look in their own "books".

If one wishes to reward incompetence or simply support the usurpation of one's rights, then, folks should continue submitting to the illegal demands.

Best.

[19K]

Originally Posted by sbo80

^thanks for the clarity, I guess I over exaggerated. Seems the FFL keeps a copy of your 03 but doesn't actually send it on to the DOJ. I didn't know that part, just that I've always handed it over.
The other part is still valid. BOF961 (Collector In-State Acquisition) and BOF4100 (C&R Firearm Report) both explicitly require your # on the form. Those of us that do transactions without DROS, already give up our number. If you don't do those and are only using your 03 for ammo purchases and skipping 10-day waits, then I guess you can continue to keep your FFL# a secret from DOJ.

It has nothing to do with being secretive, it has to do with not complying with a request from an over reaching government entity that uses a vague threat of not being able to process a document unless you give them information that isn’t required by law.


If they ask you to start giving them your medical history, would you give it to them?

If they ask you to put down your religion and party affiliation? (Don’t have a problem with that because the DMV already has it?)

Unless what they are asking for is required by law, they have absolutely 0 business asking you for that information. It’s not just a “haha! Watch me be secretive and mysterious!” It has to do with not complying with an overreaching government agency that constantly ****s on our rights.

[G. Freeman]

Thanks so much for the responses folks. This process has been a PITA in the last 3 yrs I've been doing this. Really, just doing this for the ability to buy ammo online. Will update you guys as to the result.

[tonyl]

I had the same issue started two years ago. For this year renewal, I just enter my 03 number as part of collector section. It has been over 30 days and it is still being processed.

[SkyHawk]

Originally Posted by tonyl

I had the same issue started two years ago. For this year renewal, I just enter my 03 number as part of collector section. It has been over 30 days and it is still being processed.

Mine took 36 days this year. I did not get asked about my 03 FFL, perhaps because it is in my CFARS profile

[1bulletBarney]

Last year when I submitted my COE renewal app I got the email from CADOJ that my app was incomplete and they wanted me to add my FFL 03 number. I copied & pasted a post from Dvrjon and challenged the DOJ on this issue. They completed the app and I got my COE updated without giving in...

I am done. The last time I used my FFL 03 & COE was when we could still have C&R long guns shipped to the address listed on the 03. We could snail mail a paper "notice of C&R acquisition" form to the CADOJ. CFARS is and has been FUBAR from the beginning. Sure, it's cheaper to renew the COE annually then to start from scratch. Other than being exempt from handgun 1 in 30 or exempt from 10 day hostage of C&R firearms, finding a vendor that will ship bulk ammo to your door or instate C&R long gun face to face transfer between COE/FFL 03's, I am done...

The joy is gone. When my FFL 03 expires I will shred documented info from my bound book and call it a day...

[G. Freeman]

So I got an incomplete notice today despite already having my renewed FFL info in my profile. The "comments" section would not take any info. When I hit submit, it just erases what I enter.

Tried to upload another document under "court documents" but it won't take a word document. Would have to take a pic which I don't want to do.

Everytime I renew, this takes such a long time and make my blood boil. This state has pretty much successfully clamped us down on every level possible.

Sent the email stating the fact that my FFL info is already in my profile.

[Dvrjon]

Originally Posted by G. Freeman

So I got an incomplete notice today despite already having my renewed FFL info in my profile. The "comments" section would not take any info. When I hit submit, it just erases what I enter.

Tried to upload another document under "court documents" but it won't take a word document. Would have to take a pic which I don't want to do.

Everytime I renew, this takes such a long time and make my blood boil. This state has pretty much successfully clamped us down on every level possible.

Sent the email stating the fact that my FFL info is already in my profile.

You can always tell them, "No".

[Odd_Ball]

2022 COE Renewal Timeline:

Renewal completed within 3 business days after declining to provide the FFL03 number.

• 09/28/2022 Renewal Submitted online (uploaded scan of DL)
• 11/01/2022 Received email notice of missing FFL03 number, incomplete application
• 11/02/2022 Replied by email declining to give FFL03 number and requesting completion of renewal application processing.
• 11/04/2022 Updated Renewal App on CFARS declining to give FFL03 & submitted an Issue report explaining the same. (NOTE: not sure if this is necessary)
• 11/07/2022 COE renewed (email received at 1:01 AM, Nov 7)

[Odd_Ball]

Originally Posted by G. Freeman

So I got an incomplete notice today despite already having my renewed FFL info in my profile. The "comments" section would not take any info. When I hit submit, it just erases what I enter.

I noticed the same thing when I was trying to add in the Comment field my sample email below explaining that the FFL03 is not required for them to complete the renewal application.

My comments kept disappearing when submitting, though maybe they are visible to the DOJ.

Originally Posted by G. Freeman

Sent the email stating the fact that my FFL info is already in my profile.

Sample email response below declining to provide the FFL03 number & requesting completion of the renewal.

Would you please provide me with the reasons and authorities for requiring this information? As my COE expires within XX days, I would appreciate a response to this request within the next Y days.

Alternatively, please accept the documentation I have submitted as meeting the stated requirements of statute and regulation and complete processing of my COE. Please see 11 CCR § 4037 quoted below (emphasis added).

Thank you in advance.


https://www.law.cornell.edu/regulations/california/11-CCR-4037


11 CCR § 4037
§ 4037. Renewal of Certificate.
(a) A COE shall be renewed prior to expiration in order to remain valid. Completed applications for a COE renewal shall be submitted electronically within 60 days prior to the expiration of the certificate.
(b) Application renewal shall occur through CFARS by clicking the link “Renew COE”. Applicants shall electronically provide the following information to complete the renewal application:

(1) Applicant's full name; driver license type and identification number; email address; date of birth; residence street address; phone number; gender; United States citizenship; if not a United States citizen, the country of citizenship and the federal Alien Registration Number or federal I-94 number; and business type(s).

[kendog4570]

Slightly off topic, but when I moved I submitted for and received an AMENDED 0-1 FFL from ATF. Two digits were different from the original denoting I was now in a different federal district, otherwise everything else is the same except for address change. When time to renew my COE and other CA DOJ stuff they went bugf*@k and demanded I go through the entire COE process again. I told the flunky on the phone (this was way before CFARS) it is not a new license, it is amended, and to go look it up or ask their daddy, or whatever they had to do. Asked them to quote me chapter and verse where it said I had to do all that over again. Never got an answer, just my renewals a few days later with the amended addresses and such.
Don't let them make up rules and laws on you.

[G. Freeman]

I really appreciate all your responses. Yeah, next yr will no longer give my FFL-03 number and play their games. I appreciate also with the sample responses.

Will update you guys of the results.

[EM2]

tagged
thanks for the heads up, submitted my renewal a couple weeks ago.

[dummykid]

I submitted my renew on 11/03/2022, and its still pending.

[G. Freeman]

Gents,

Thanks so much for all your input. Here's the update:

Renewal sent 10/3. It was due to expire 11/20/22.
My FFL info was already under my profile when I renewed on 10/3.

11/6: notice of incomplete from CFARS requesting FFL-3. On the same day, I sent a response about my FFL info by forwarding a response to the COE@doj.ca.gov email.

11/15: No response yet so I sent another email directly to COE@doj.ca.gov

11/19: Approved

[1911-CV]

The FFL03 is not required, and the DOJ will process the renewal without it when there is any push back from the applicant. But folks like G. Freemen get a request for the FFL03 when it is already in their profile.

Seems like this is all on autopilot with the DOJ staff just going through the motions.

[Dvrjon]

Originally Posted by G. Freeman

I really appreciate all your responses. Yeah, next yr will no longer give my FFL-03 number and play their games. I appreciate also with the sample responses.

Will update you guys of the results.

I’d suggest copying this thread into an electronic calendar on a date 2 months from your next expiration date.

[EM2]

I received the CFARS FFL-03 email today, and I am within 9 days of expiration.

From: coe@doj.ca.gov

To:EM2

Subject: California Firearms Application Reporting System (CFARS) Incomplete Notice

EM2

The California Department of Justice has received your electronic Certification of Eligibility (COE) application; however, it cannot be processed for the following reason(s): * Please provide your Federal Firearms License (FFL) Type 03 Collector of Curios and Relics FFL Number via email to the COE Unit at: COE@doj.ca.gov . If you do not have an FFL-03, please indicate the reason for wanting a COE in the email. Also be sure to include your first and last name and California Driver?s License/Identification Card number in your email response, thank you!
The information requested should be submitted by logging into the CFARS application https://cfars.doj.ca.gov and navigating to Certificate of Eligibility and selecting "COE Transaction History". If you have any questions, please use the Report an Issue feature in the CFARS application.

Thanks to 19K and Dvrjon I have provided the following response.

CFARS has notified me that my COE application is incomplete, indicating that I must submit an FFL-03 license to complete processing.

I have not been asked for this information during initial application or previous renewals. Would you please provide me with the reasons and authorities for requiring this information?
As my COE expires within 9 days, I would appreciate a response to this request no later than next week.
Alternatively, please accept the documentation I have submitted as meeting the stated requirements of statute and regulation and complete processing of my COE.

Thank you in advance for your favorable consideration.

EM2

I will let you know how it turns out.
And thanks everyone for the inspiration to push back against the gov.

[Mezcalfud]

My outlook reminder came up this weekend and I processed the renewal today, so I am 58 days until expiration.

I have always been luck with renewal timelines but have been reading of long delays past expiration. There has to be some recourse to the DOJ delaying processing?

[G. Freeman]

IDK, however, like all things DOJ they appear to have a lot of backlog. In the event they claim your application is "incomplete", we seem to have a lot of success documented here in CG after we provide that pushback response.

[EM2]

OK, just got my 2023 COE today, here is my timeline.

Nov-5th - Submitted renewal application
Dec-10th - Received email stating my application is incomplete and they are requesting my FFL-03 #.
Dec-10th - I reply, refusing to provide the FFL-03 # and asked them to provide the applicable statute that required the FFL-03 # be provided.
Dec-20th - My COE expires, I logged onto CFARS to check status, and still showing incomplete application.
Dec-23rd - received email stating my application was "In Progress".
Dec-24th - I received email stating there was a important information regarding my application. I logged onto CFARS and saw the 2023 COE.
7-weeks total.

[G. Freeman]

EM2 awesome man. Thx for the update. Merry Christmas to u too.

[Dvrjon]

Originally Posted by EM2

OK, just got my 2023 COE today, here is my timeline.

Nov-5th - Submitted renewal application
Dec-10th - Received email stating my application is incomplete and they are requesting my FFL-03 #.
Dec-10th - I reply, refusing to provide the FFL-03 # and asked them to provide the applicable statute that required the FFL-03 # be provided.
Dec-20th - My COE expires, I logged onto CFARS to check status, and still showing incomplete application.
Dec-23rd - received email stating my application was "In Progress".
Dec-24th - I received email stating there was a important information regarding my application. I logged onto CFARS and saw the 2023 COE.
7-weeks total.

Another winner!

Seriously, how good did that feel?

[EM2]

Originally Posted by Dvrjon

Another winner!

Seriously, how good did that feel?

Pretty good
Thanks for your advise and guidance.

[Mezcalfud]

approx 30 days in- I got my FFL request email

"Despite this request being invalid, I have erroneously provided the requested information on past renewals and a FFL03 is on file. If there is continued insistence of resubmission, please advise where a FFL03 requirement is stated in the application process or in the applicable code. Otherwise, I ask that my renewal be processed and that you cease requesting information that is not legally required.

Thank you."

[Pocket Rocket]

Submitted my renewal on Dec 18th, and my COE expired on the Dec 20th. I’m still waiting on the email asking for a copy of my 03FFL. It’s in my profile if they want it, but I’m not planning to upload it.

What will be interesting is my CA DL expires in a week. Guess we’ll see if they try to state that my DL is now longer valid if they try to process after the expiration date.

[Pocket Rocket]

As predicted the day my DL expires they email asking for a copy of my 03FFL License. I politely declined citing to the regulations that it was not required for renewal, and all required / valid documents had been provided at initial submission.

I noted in my email that the DL used for ID purposes has now expired due to the delay in processing my renewal, and could re-upload an unexpired ID if needed.

We’ll see what happens.

[mickri]

I scanned my FFL03 card and my DL on the same document. Uploaded it yesterday evening as part of my renewal. My COE doesn't expired until 3/20/2023.

[Dvrjon]

Originally Posted by Mezcalfud

approx 30 days in- I got my FFL request email

"Despite this request being invalid, I have erroneously provided the requested information on past renewals and a FFL03 is on file. If there is continued insistence of resubmission, please advise where a FFL03 requirement is stated in the application process or in the applicable code. Otherwise, I ask that my renewal be processed and that you cease requesting information that is not legally required.

Thank you."

No reason to be abrupt or rude. They’re entry-level analysts following the checklist management provided. Like the reed, when pushed, management bends.