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So as not to spam up any other threads (more than they already have been). I thought I would start a new thread to inform C&R licensee's of their record keeping requirements after their licenses expire.
So once and for all, direct from the BATFE. Not my opinion, and not from a random Agent. These directives are direct from the BATFE Licensee newsletters.
C&R licensee's ARE NOT REQUIRED TO KEEP THEIR RECORDS AS REQUIRED IN 27 CFR 478.129(e) if they are no longer a licensee.
BATFE "suggests" that you keep the records, but it is not a requirement of law.
See page (7) in the below 2004 BATFE news letter link. . The BATFE explicitly says records kept by C&R licensee's "ARE NOT BUSINESS RECORDS"
"Licensed collectors are not required to turn in their acquisition / disposition records if their license is not renewed or they discontinue their collecting activity. The GCA requires the delivery of required records to the Government within 30 days after a firearms “business” is discontinued.
A license as a collector of curios or relics does not authorize any
business with respect to firearms.
This is in contrast to firearms importers, manufacturers, and dealers who are licensed to engage in a firearms business.
Therefore, the records required to be kept by licensed collectors under the law and regulations are not business records and are not required to be turned in to ATF when collector’s licenses. "
More from a BATFE 2011 news letter. See page (5) This specifically says record retention as specified in 27 CFR 478.129(e) IS NOT REQUIRED
"ATF receives numerous inquiries concerning record retention requirements applicable to holders of Collector
of Curios or Relics (C&R) licenses that discontinue their
collection activities and do not renew their licenses. If
someone who held a C&R FFL is no longer a licensee,
then he or she is no longer required to comply with
ATF regulation of licensees, which includes the record
retention requirement specified in 27 CFR 478.129(e).
In addition, C&R licensees are not required to submit
their A&D records to the ATF Out-of-Business Records
Center."
However, we suggest that all C&R records be
retained for future reference.
Additionally, there may be State laws pertaining to C&R
FFLs. C&R licensees should contact the appropriate
State attorneys general office or other appropriate State
agencies to inquire about these laws. A list of State attorneys general offices, with contact information, may be
found at http://www.naag.org.
So once and for all, direct from the BATFE. Not my opinion, and not from a random Agent. These directives are direct from the BATFE Licensee newsletters.
C&R licensee's ARE NOT REQUIRED TO KEEP THEIR RECORDS AS REQUIRED IN 27 CFR 478.129(e) if they are no longer a licensee.
BATFE "suggests" that you keep the records, but it is not a requirement of law.
See page (7) in the below 2004 BATFE news letter link. . The BATFE explicitly says records kept by C&R licensee's "ARE NOT BUSINESS RECORDS"
"Licensed collectors are not required to turn in their acquisition / disposition records if their license is not renewed or they discontinue their collecting activity. The GCA requires the delivery of required records to the Government within 30 days after a firearms “business” is discontinued.
A license as a collector of curios or relics does not authorize any
business with respect to firearms.
This is in contrast to firearms importers, manufacturers, and dealers who are licensed to engage in a firearms business.
Therefore, the records required to be kept by licensed collectors under the law and regulations are not business records and are not required to be turned in to ATF when collector’s licenses. "
More from a BATFE 2011 news letter. See page (5) This specifically says record retention as specified in 27 CFR 478.129(e) IS NOT REQUIRED
"ATF receives numerous inquiries concerning record retention requirements applicable to holders of Collector
of Curios or Relics (C&R) licenses that discontinue their
collection activities and do not renew their licenses. If
someone who held a C&R FFL is no longer a licensee,
then he or she is no longer required to comply with
ATF regulation of licensees, which includes the record
retention requirement specified in 27 CFR 478.129(e).
In addition, C&R licensees are not required to submit
their A&D records to the ATF Out-of-Business Records
Center."
However, we suggest that all C&R records be
retained for future reference.
Additionally, there may be State laws pertaining to C&R
FFLs. C&R licensees should contact the appropriate
State attorneys general office or other appropriate State
agencies to inquire about these laws. A list of State attorneys general offices, with contact information, may be
found at http://www.naag.org.
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