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Federal L.E.O. Exemption X-32, Supporting Documentation?

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  • c good
    Veteran Member
    • Oct 2005
    • 2638

    Federal L.E.O. Exemption X-32, Supporting Documentation?

    One part of the exemptions on the D.O.J. says get a department letter, then another part says just write down the Name, Federal Agency Affiliation, and credential number. So....department letter or just record the above info. Can't copy a federal I.D. Thanks for any input on this. c good
    Last edited by c good; 09-09-2015, 8:48 PM.
  • #2
    RickD427
    CGN/CGSSA Contributor - Lifetime
    CGN Contributor - Lifetime
    • Jan 2007
    • 9264

    Originally posted by c good
    One part of the exemptions on the D.O.J. says get a department letter, then another part says just write down the Name, Federal Agency Affiliation, and credential number. So....department letter or just record the above info. Can't copy a federal I.D. Thanks for any input on this. c good
    You are permitted to copy a federal ID if done in compliance with a law, or a regulation adopted pursuant to a law.

    A lot of uninformed folks like to cite the prohibition on copying of federally issued documents without citing the corresponding exceptions.

    Please refer to 18 USC 701. Here is the text with the applicable part in bold:

    "Whoever manufactures, sells, or possesses any badge, identification card, or other insignia, of the design prescribed by the head of any department or agency of the United States for use by any officer or employee thereof, or any colorable imitation thereof, or photographs, prints, or in any other manner makes or executes any engraving, photograph, print, or impression in the likeness of any such badge, identification card, or other insignia, or any colorable imitation thereof, except as authorized under regulations made pursuant to law, shall be fined under this title or imprisoned not more than six months, or both."
    Last edited by RickD427; 09-09-2015, 7:00 PM.
    If you build a man a fire, you'll keep him warm for the evening. If you set a man on fire, you'll keep him warm for the rest of his life.

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    • #3
      teg33
      Veteran Member
      • May 2013
      • 3441

      Please define " Authorized under regulations made pursuant to law". Thanks

      Comment

      • #4
        c good
        Veteran Member
        • Oct 2005
        • 2638

        My corporate big wigs say "no copying of federal I.D.'s" In their mind they are the higher power. But I'm interested in "except as authorized under regulations made pursuant to law" clause. I don't seem to be able to find anything about this after doing some searching......

        So at this point......Do I get a Department letter or just write down name, federal agency affiliation, and credential number for supporting documentation? Thanks. c good
        Last edited by c good; 09-09-2015, 8:12 PM.

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        • #5
          RickD427
          CGN/CGSSA Contributor - Lifetime
          CGN Contributor - Lifetime
          • Jan 2007
          • 9264

          Originally posted by teg33
          Please define " Authorized under regulations made pursuant to law". Thanks
          It's really pretty self-explanatory.

          Both California State and the Feds have a body of government regulations. They are administrative regulations that agencies were authorized by law to adopt, and to enforce. For California that would include the content of the California Code of Regulations, and specific agency regulations that were adopted under the authority of a statute.
          If you build a man a fire, you'll keep him warm for the evening. If you set a man on fire, you'll keep him warm for the rest of his life.

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          • #6
            c good
            Veteran Member
            • Oct 2005
            • 2638

            So can I legally copy a federal I.D. for supporting documentation pertaining to the X-32 exemption (regardless of my corporate policy)?

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            • #7
              RickD427
              CGN/CGSSA Contributor - Lifetime
              CGN Contributor - Lifetime
              • Jan 2007
              • 9264

              Originally posted by c good
              So can I legally copy a federal I.D. for supporting documentation pertaining to the X-32 exemption (regardless of my corporate policy)?
              I would first make sure that there is a DOJ regulation requiring that and that the DOJ regulation has a statutory basis.
              If you build a man a fire, you'll keep him warm for the evening. If you set a man on fire, you'll keep him warm for the rest of his life.

              Comment

              • #8
                c good
                Veteran Member
                • Oct 2005
                • 2638

                Originally posted by c good
                One part of the exemptions on the D.O.J. says get a department letter, then another part says just write down the Name, Federal Agency Affiliation, and credential number. So....department letter or just record the above info. Can't copy a federal I.D. Thanks for any input on this. c good
                DOJ only mentions above options. DOJ also says I can't copy a federal I.D. I thought you knew that when you mentioned the exception. So it looks like CA DOJ trumps federal statute on copy of federal I.D. I guess I should have clarified that corporate policy per CA DOJ statute precludes me copying a federal I.D. In my above post.

                So back to my original question again....Department letter or Name, Federal Agency affiliation, and credential number.

                Thanks all for any input. c good

                Comment

                • #9
                  kw91364
                  Junior Member
                  • Jul 2009
                  • 62

                  I personally know an FFL who was written up by the ATF during an audit, specifically for photocopying federal agents credentials. He was told it was not allowed under federal law. After the audit his new policy was to only visually look at the creds to verify their LE status, but not photocopy them. He would then make a copy of the agent's *business card* and wrote down their cred number on the photocopy of the business card and kept it with the paperwork in case of an audit.
                  Last edited by kw91364; 09-09-2015, 9:06 PM.

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                  • #10
                    c good
                    Veteran Member
                    • Oct 2005
                    • 2638

                    Originally posted by kw91364
                    I personally know an FFL who was written up by the ATF during an audit, specifically for photocopying federal agents credentials. He was told specifically it was not allowed. After the audit his new policy was to only visually look at the creds to verify their LE status, but not photocopy them. He would then make a copy of the agent's *business card* and wrote down their cred number on the photocopy and kept it with the paperwork in case of an audit.
                    Thank you so much for your response. This is EXACTLY what I was hoping to clarify. c good

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                    • #11
                      ugimports
                      Vendor/Retailer
                      • Jun 2009
                      • 6250

                      We write down the agency and credential ID number and keep with copy of CA DL/ID.
                      UG Imports - Fremont, CA FFL - Transfers, New Gun Sales
                      Closure Schedule: http://ugimports.com/closed
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                      • #12
                        ArmsUnlimited
                        Senior Member
                        • Sep 2012
                        • 1290

                        Just copy the federal guys' business card and you are good to go
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                        • #13
                          Bobshouse
                          Senior Member
                          • Oct 2005
                          • 516

                          Originally posted by c good
                          Thank you so much for your response. This is EXACTLY what I was hoping to clarify. c good
                          Perfect example of the internet at work. Just wait and you will eventually get the answer you wanted. Might not be the right answer, but it's the one you wanted...now your covered!

                          I would not let anyone copy my credentials, for any reason.

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                          • #14
                            BONECUTTER
                            Senior Member
                            • Aug 2007
                            • 2263

                            I've been over this a few time and just follow what the FSC manual says and never had an issue.

                            DOJ will not accept a firearm DROS transaction for processing unless it has the FSC number or the appropriate exemption status code recorded on it.
                            I did always find it odd that the CA DOJ did not include Military ID's in that exemption.

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                            • #15
                              Condorguns
                              Still lost in the desert
                              CGN Contributor - Lifetime
                              • Dec 2007
                              • 3302

                              Originally posted by BONECUTTER
                              I've been over this a few time and just follow what the FSC manual says and never had an issue.



                              I did always find it odd that the CA DOJ did not include Military ID's in that exemption.
                              Nope.... Military is not exempt. You will also notice that on the back of Fed ID is has a notice that it is a crime to photocopy it. There is no such notice printed on Military ID.
                              You, you, and you: Panic. The rest of you, come with me.
                              Incoming fire has the right of way.

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