Question on Multiple Handgun Sales Form

[ugimports]

Scenario: Customer picked up 2 PPTs today AND I ran them a re-DROS on a C&R that went through Digital Instincts. They brought the revolver in, had an FFL03 and COE.

Question: Does the revolver that went out with the C&R/COE go on the multiple handgun sales form? I didn't do a 4473 - just DROS.

Answer: I think the answer is No, but I'm not 100% sure.

[ugimports]

Well I think I just found an answer to my current situation: "This form is not required when the pistols or revolvers are returned to the same person from whom they are received".

My situation is unique in that he brought it in because DOJ told him he had to re-DROS it. However, assuming this came in from out of state I'm not clear. I think #1 on the instructions does clarify that if they are "unlicensed" it doesn't get reported. So does that mean since he's an FFL03 that I don't report ANY of these, including the PPTs of modern pistols?

[ke6guj]

I would opine that the person was not an unlicensed person as it applies to the C&R handgun so you would only list the modern handguns on that form.

1. This form is to be used by licensees to report all transactions in which an unlicensed person acquired two or more pistols or revolvers or any combination
of pistols or revolvers totaling two or more at one time or during five consecutive business days. This form is not required when the pistols or revolvers
are returned to the same person from whom they are received.

https://www.atf.gov/file/61426/download


ATF seems to feel that 03FFLs are only considered "licensed" when dealing with C&R firearms. otherwise, I would be able to use my 03FFL to exempt myself from the federal handgun safety lock law for C&R and modern handguns.

[ugimports]

I think that sounds about right as well. I'll go with that and contact them in parallel and correct if necessary.