Let's talk about record keeping ...

[RoundEye]

So, I heard early on that you should keep the CADOJ paperwork separate from the Federal ATF paperwork so when it comes time for a CADOJ Audit, you give them only the CA stuff, and when the ATF comes to do an Audit you give them only the Federal stuff.

Is this how most of you are doing it? If so, is this the list of documents that should be maintained in each packet?

CADOJ

1. DROS
2. FSC (or exempting document)
3. Safe Handling
4. CDL
5. Safe Affidavit (if applicable)
6. Proof of residency

ATF

1. 4473
2. Log Book

*Am I missing anything?

If you keep everything separate for each do you keep two copies of the CDL and Proof of Residency (one for each agency packet) since both agencies require them?

How about for gun traces, do you keep an internal database of all your sales (Customer, Serial, Make, and Model), so you can easily do a search should the ATF call with a trace, or do you go through your boxes of paperwork?

I'm currently keep all the paperwork together, and just want to make sure I'm doing it the best way before I have some much paperwork that the effort would be a huge ordeal.

[taperxz]

So, I heard early on that you should keep the CADOJ paperwork separate from the Federal ATF paperwork so when it comes time for a CADOJ Audit, you give them only the CA stuff, and when the ATF comes to do an Audit you give them only the Federal stuff.

Is this how most of you are doing it? If so, is this the list of documents that should be maintained in each packet?

CADOJ

1. DROS
2. FSC
3. Safe Handling
4. CDL
5. Safe Affidavit (if applicable)
6. Proof of residency?

ATF

1. 4473
2. CDL
3. Proof Residency
4. Log Book

*Am I missing anything?

If you keep everything separate for each do you keep two copies of the CDL and Proof of Residency (one for each agency packet) since both agencies require them?

How about for gun traces, do you keep an internal database of all your sales (Customer, Serial, Make, and Model), so you can easily do a search should the ATF call with a trace, or do you go through your boxes of paperwork?

I'm currently keep all the paperwork together, and just want to make sure I'm doing it the best way before I have some much paperwork that the effort would be a huge ordeal.

For ATF you don't need copies of the DL or proof of residency. You should keep multiple handgun sales with the 4473. If you sell a firearm to a visa holder, you should retain a copy of the hunting license.

[RoundEye]

For ATF you don't need copies of the DL or proof of residency. You should keep multiple handgun sales with the 4473. If you sell a firearm to a visa holder, you should retain a copy of the hunting license.

Cool, updated.

With the multiple firearms sales they're logged on the 4473 (page 3?). Is that what you mean?

Good point about the Visa holder, I wasn't really thinking about the special cases.

[taperxz]

Cool, updated.

With the multiple firearms sales they're logged on the 4473 (page 3?). Is that what you mean?

Good point about the Visa holder, I wasn't really thinking about the special cases.

No, whenever you sell multiple handguns in one sale or within 5 days of each other to one person, we are required to fill out a multiple sale of handguns report and send a copy to ATF and your local LE. We retain a copy of that with the 4473 for easy inspection

[RoundEye]

No, whenever you sell multiple handguns in one sale or within 5 days of each other to one person, we are required to fill out a multiple sale of handguns report and send a copy to ATF and your local LE. We retain a copy of that with the 4473 for easy inspection

Oh, okay gotcha. If I recall correctly, I think there's also a similar requirement for semi-automatic rifles as well.

Does that apply to transfers of the FFL Holder as well? I think the only time I have ever sold multiple handguns to someone in a 5 day period was to myself.

[acespawnshop]

We do the following:

When we initiate a DROS we get the following
1.Checklist
2. 4473
3. Copies of ID/DL, FSC or exemption, proof of residency if handgun.
4. Pending DROS
5. Safety demo, if necessary
6. Safe affidavit it necessary
7. Aces Customer agreement.

We do the DROS, put the checklist on top and staple and file away for 10 day wait.

On day of pick up.

We take the packet and print approval. Then once customer is done we do this.

1. Dispose in pawn master (we use it as a backup for our A&D since it backsup to the cloud every 2 hours)
2. Dispose in actual A&D.
3. Separate 4473 (staple multi handguns, multi rifles if necessary to 4473. )
4. DROS packet stapled together for DOJ in the following order
a. Approval DROS
b. Pending DROS
c. Copy of ID/DL, FSC, and proof of residency
d. Safety demo if required
e. Safe affidavit (don't forget to date day of pick up)
5. Aces customer agreement

We have 3 bankers boxes labeled "ATF" "DOJ" and "ACES"

We put the 4473 in ATF
We put the DROS packet in the DOJ
We put the customer agreement in the ACES

They stay in a nice order from the day of pick up and we usually have two or three bankers boxes for ATF and DOJ per year. We put the dates on the outside boxes and store them on the highest shelf away.

On occasion while the paperwork is still down low in the most current ATF or DOJ box we will have one of the managers go through the paperwork to check for ATF and DOJ compliance, we use sticky notes to denote where he left off so as more get piled on top we know whats been checked and hasn't.

Bing, bang, boom, easy peasy lemon squeezy.


We also maintain 3 ring binders that are labeled with the dates for incoming FFL's, CFLCs and invoices. We print a sticker that shows the stock number for that appropriate gun(s) and put it on the paperwork and file those in order from date arrived.

We have a 3 ring binder for OUTGOING transfers. Who we sent the firearm to, a copy of their FFL, and the tracking number along with a sales receipt generated by pawnmaster for the "sale" of that firearm.

We have a 3 ring binder for ID's and Thumbprints for firearms acquired in the DES under Pawn or Buys. These are separated by Month and put in order as we acquire them, we also have the customer sign our customer agreement and since its not for a sale this customer agreement goes with the ID and acquisition paperwork in the binder.

[acespawnshop]

If you sell a firearm to a visa holder, you should retain a copy of the hunting license.

We mark their GO ID info on the 4473 in the box for question 31. I feel that is sufficient as there is no requirement we retain the copy. Just document it.

[kemasa]

As strange as it might seem, the Feds don't have a requirement to copy documents, although you do have to document it, such as writing what it is on 18b.

This means that there is a good separation between state and federal.

The multiple purchase, both for handguns and long guns (depending on how you are licensed and where you are located since it isn't required in some states) is federal and only for those not licensed. A person with a C&R FFL isn't licensed with respect to modern firearms.

Remember that for the multiple purchases, it is YOUR BUSINESS days, not calendar days or normal business days. If you are only open 1 day per week, then it would end up being 5 weeks.

Also, again, as strange as it seems, there is no CA proof of residency for long guns.

[taperxz]

Oh, okay gotcha. If I recall correctly, I think there's also a similar requirement for semi-automatic rifles as well.

Does that apply to transfers of the FFL Holder as well? I think the only time I have ever sold multiple handguns to someone in a 5 day period was to myself.

If you are required to fill out a 4473 then yes.

FYI if someone does a PPT and buys a gun from you, it is a multiple handgun sale. Private party transfers in your store count

[RoundEye]

We do the following:

When we initiate a DROS we get the following
1.Checklist
2. 4473
3. Copies of ID/DL, FSC or exemption, proof of residency if handgun.
4. Pending DROS
5. Safety demo, if necessary
6. Safe affidavit it necessary
7. Aces Customer agreement.

We do the DROS, put the checklist on top and staple and file away for 10 day wait.

On day of pick up.

We take the packet and print approval. Then once customer is done we do this.

1. Dispose in pawn master (we use it as a backup for our A&D since it backsup to the cloud every 2 hours)
2. Dispose in actual A&D.
3. Separate 4473 (staple multi handguns, multi rifles if necessary to 4473. )
4. DROS packet stapled together for DOJ in the following order
a. Approval DROS
b. Pending DROS
c. Copy of ID/DL, FSC, and proof of residency
d. Safety demo if required
e. Safe affidavit (don't forget to date day of pick up)
5. Aces customer agreement

We have 3 bankers boxes labeled "ATF" "DOJ" and "ACES"

We put the 4473 in ATF
We put the DROS packet in the DOJ
We put the customer agreement in the ACES

They stay in a nice order from the day of pick up and we usually have two or three bankers boxes for ATF and DOJ per year. We put the dates on the outside boxes and store them on the highest shelf away.

On occasion while the paperwork is still down low in the most current ATF or DOJ box we will have one of the managers go through the paperwork to check for ATF and DOJ compliance, we use sticky notes to denote where he left off so as more get piled on top we know whats been checked and hasn't.

Bing, bang, boom, easy peasy lemon squeezy.


We also maintain 3 ring binders that are labeled with the dates for incoming FFL's, CFLCs and invoices. We print a sticker that shows the stock number for that appropriate gun(s) and put it on the paperwork and file those in order from date arrived.

We have a 3 ring binder for OUTGOING transfers. Who we sent the firearm to, a copy of their FFL, and the tracking number along with a sales receipt generated by pawnmaster for the "sale" of that firearm.

We have a 3 ring binder for ID's and Thumbprints for firearms acquired in the DES under Pawn or Buys. These are separated by Month and put in order as we acquire them, we also have the customer sign our customer agreement and since its not for a sale this customer agreement goes with the ID and acquisition paperwork in the binder.

Thank you, this is exactly the kind of feedback I was looking for.

[BONECUTTER]

I don't separate 4473 & DROS records and keep it all together. I really don't care if they want to look at it.

[acespawnshop]

A plus to separating them is after 3 years it’s easy to chuck the CA nonsense.

[ugimports]

I don't separate 4473 & DROS records and keep it all together. I really don't care if they want to look at it.

Here's what I'm afraid could happen..

Driver's License says weight is 200 pounds (so that ends up on DROS)
4473 says weight is 180 pounds (that's what they input)

DOJ tells you since the current weight on 4473 is 180 pounds that what you have on DROS is 200 pounds is inaccurate. Cancel and re-run DROS.

Now...I don't know if that's ever happened, but I don't want to invite that possibility by letting them see anything on the 4473 that might be different then the DROS and use that as a basis to tell me I did the DROS wrong.

[BONECUTTER]

Here's what I'm afraid could happen..

Driver's License says weight is 200 pounds (so that ends up on DROS)
4473 says weight is 180 pounds (that's what they input)

DOJ tells you since the current weight on 4473 is 180 pounds that what you have on DROS is 200 pounds is inaccurate. Cancel and re-run DROS.

Now...I don't know if that's ever happened, but I don't want to invite that possibility by letting them see anything on the 4473 that might be different then the DROS and use that as a basis to tell me I did the DROS wrong.

I've been through 5 or 6 DOJ audits and never had them care about anything like that. I have heard stories of other FFL's giving them hard times. Making them work in hot rooms, calling them curse words constantly, having a Lawyer come in to watch there every move. I get the DOJ hate but at the end of the day the auditors I have dealt with (4 different ones) have all been friendly and not "out to get me".

[taperxz]

Here's what I'm afraid could happen..

Driver's License says weight is 200 pounds (so that ends up on DROS)
4473 says weight is 180 pounds (that's what they input)

DOJ tells you since the current weight on 4473 is 180 pounds that what you have on DROS is 200 pounds is inaccurate. Cancel and re-run DROS.

Now...I don't know if that's ever happened, but I don't want to invite that possibility by letting them see anything on the 4473 that might be different then the DROS and use that as a basis to tell me I did the DROS wrong.

Thats it! Now we have to have a scale to weigh people with in order to deliver a firearm.