CA DOJ illegally requiring upload of FFL-03 when renewing COE

[EM2]

How does COE work for non 03s? Clerks and such. Do they need to prove they work for an FFL or something?

Yes, and that requirement is a part of the law.
When filling in the application a person has to check the COE 'type' box associated with all of their COE needs, so a store clerk would check say the gun store and/or ammo vendor box(s).
At this point there is a requirement that they provide employer information.
There are no additional requirements if you check only the 'Collector' box (FFL-03).

[MajorSideburns]

The people at CA DOJ think they are above the law. They don't care what the penal code is, they make up the law as they go. You won't get anywhere with them unless it's a court order through a legal suit. Even then, they will ignore a judge if the decision is not to their liking. They are unelected tyrants. Do you remember the "guidelines" they promulgated as law and then carried out threats of arrest for possession of "assault weapons" when people realized the new bullet button ban legislation left a few loopholes? There was nothing in the law that said you couldn't remove your bullet button after registration once you registered it as a "RAW" (California Registered Assault Weapon) yet they pushed out "rules" that forbid anyone from doing that.

[stevosmith]

just curious, what would some disadvantages be to send them the FFL3 to process the COE. I do understand it's not required by law but like to understand the disadvantage of showing them the FFL3.

[Usual_Suspect]

An employee of mine ran into this about 2 weeks ago, he has had an FFL03 for years. He said DOJ dug their heels in, and would not budge. He said he called, and DOJ told him, they cannot verify FFL03's online, it is a manual process, and that is how they are verifying he has an FFL03. They need proof, his FFL03 wallet card would suffice, so that is what he ended up giving them. His COE was approved the following day. Sad how the powers to be keep moving the goal posts.

[P5Ret]

Just to add a bit more fuel to the fire. My COE just renewed today, sent in the renewal on 12/30, I was not asked to provide anything other than my DL.

[Capybara]

I just tried to renew my COE and received the same stupid email as EM2 did yesterday. EM2, where so you stand, are you in a Mexican standoff with them or did they shrug their shoulders and finally issue your COE without sending them the FFL03?

[EM2]

I Shrugged, after about the third email that kept reiterating their position.
No matter any of my points, they kept ignoring my logic and stated they could not process my renewal without my FFL document.
They didn't even have the courtesy to acknowledge my points, they just copy & pasted their previous email.

[Capybara]

I needed my FFL03 to order some ammo so I reluctantly sent them my wallet card. I'm ashamed I bowed to their bullshyte but they hold all of the cards. It seems its either lick their boots or no COE. I don't how I can live with myself.

[19K]

I got my state senator and assemblyman involved with this issue. They started an official inquiry and the DOJ dug in deep and repeated the same lines.
I emailed them daily with the PC and regulations that show I wasn’t required to send it. All their PCs I quoted in ever single email and highlighted the sections they referenced asking where in that section did it state I must provide proof of having an FFL. If you are on Reddit you saw, it was a big thread

I eventually caved into however, I sent them a redacted photo, I blacked out my FFL number but kept my name/address and the license type and expiration date visible and it was approved.

[chrisw]

I got my state senator and assemblyman involved with this issue. They started an official inquiry and the DOJ dug in deep and repeated the same lines.
I emailed them daily with the PC and regulations that show I wasn’t required to send it. All their PCs I quoted in ever single email and highlighted the sections they referenced asking where in that section did it state I must provide proof of having an FFL. If you are on Reddit you saw, it was a big thread

I eventually caved into however, I sent them a redacted photo, I blacked out my FFL number but kept my name/address and the license type and expiration date visible and it was approved.

Interesting. It sucks to give in to those bastards but I like your method

[NapalmCheese]

As I understand it, they are requiring you submit your FFL when you check "collector" as your role for your COE.

So if you don't check "collector" they shouldn't require the FFL right? And if as asserted previously in this thread that anyone can get a COE, then why not apply for it NOT as a collector?

As for file type, it says in the email "use any file type". I have to do the same thing and use some other file type for other things since I refuse to get a RealID and have to upload other supporting documentation.

[EM2]

As I understand it, they are requiring you submit your FFL when you check "collector" as your role for your COE.

So if you don't check "collector" they shouldn't require the FFL right? And if as asserted previously in this thread that anyone can get a COE, then why not apply for it NOT as a collector?

As for file type, it says in the email "use any file type". I have to do the same thing and use some other file type for other things since I refuse to get a RealID and have to upload other supporting documentation.

I checked collector because that is what applies to my condition.
It would be dishonest for me to check another box.

[NapalmCheese]

Can CA require that a person getting a COE under the role "Collector" have a valid 03-FFL?

Can CA require that a person getting a COE under some other role have proof of that role?

[EM2]

Can CA require that a person getting a COE under the role "Collector" have a valid 03-FFL?

Can CA require that a person getting a COE under some other role have proof of that role?

Apparently, yes, they would not continue to process my renewal without my ffl-03 document.
They do not have the legal authority (in my opinion), but the do have the might.

[NapalmCheese]

Apparently, yes, they would not continue to process my renewal without my ffl-03 document.
They do not have the legal authority (in my opinion), but the do have the might.

It was the same for me, they wouldn't process without my documentation (FFL in this case).

What happens if someone without an 03-FFL requests a COE as 'other' and then gets an 03-FFL? Will they deny or otherwise hold up the COE? What proof will they need for 'other'.

I'm not a lawyer, I can't say they have the legal authority to require a copy of my FFL or not; but I'm guessing CalDOJ's lawyers think they do and until someone takes this in front of a judge, who's to say?