FFL PPT (Good or Bad or ? for CA FFLs)

[brogrammer]

Hello CA FFLs,

I am interested to learn your 'take' on PPTs in California (not necessarily consignments where a business owner could earn a commission).

So far as I can tell:
1. FFLs are required under state law to complete PPT DROS Transactions (except for Handguns if your store does not sell handguns)
2. There is a mandatory "cap" on the fee that can be charged ($10), in addition to the state's $37.19 fee.
3. While there is a Cap on the fee, I have heard some dealers charging a storage fee for the firearm - though this seems to contradict part of the previous code (Perhaps I am misunderstanding and storage fees, other fees, are in fact not allowed. )

28005 (c) The dealer may not charge any additional fees.

4. In order for employees to perform a DROS - firearm or ammo - employees need to have a COE. To issue FSC they must be a DOJ firearms instructor.

Leaving this aside, the usual trend I have noticed with PPTs/DROS:
1. Limited number processed (only on specific days of the week)
2. DROS PPT by appointment only
3. Some stores refusing "Off-Roster Handguns" PPT/DROS due to the nature of the "handgun"

This is not meant to be a knock-on FFLs or the PPT process, first and foremost it is your BUSINESS/LIVELIHOOD and no one expects you to risk that for $10.

It's also a complicated/time-intensive process that exposes you to liability risk with little "profit" motive

Is that the general consensus? How could it be better?

Any rants, etc. I could learn from would be appreciated!

Thanks

[acespawnshop]

How can it be better? I mean simple answer allow face to face sales like the rest of the free states.

[BONECUTTER]

There is a mandatory "cap" on the fee that can be charged ($10), in addition to the state's $37.50 fee.

$37.19

3. While there is a Cap on the fee, I have heard some dealers charging a storage fee for the firearm - though this seems to contradict part of the previous code (Perhaps I am misunderstanding and storage fees, other fees, are in fact not allowed. )

From the start of DROS to your 10 days the dealer can not charge additional fees. But if a dealer wanted to they could charge fees for every minute/hour/day after that 10 days you have not picked it up as storage fees. DOJ has said this is legal.

Limited number processed (only on specific days of the week)

Not Legal, if during there open hours they can't refuse.

DROS PPT by appointment only

If they are appointment only that's different and legal.... if they allow walk ins but not PPT's that's not legal.

Some stores refusing "Off-Roster Handguns" PPT/DROS due to the nature of the "handgun"

If the firearm is legally configured they have no legal reason not to.

Snitching to CADOJ is counter productive but blasting dealers who don't follow the laws on Calguns is a good start...

[brogrammer]

Thanks, @BUONECUTTER, updated on the fees - $37.19 for DROS from the State.

If the firearm is legally configured they have no legal reason not to.

Agreed.

Snitching to CADOJ is counter productive

Agreed.

[taperxz]

$37.19



From the start of DROS to your 10 days the dealer can not charge additional fees. But if a dealer wanted to they could charge fees for every minute/hour/day after that 10 days you have not picked it up as storage fees. DOJ has said this is legal.



Not Legal, if during there open hours they can't refuse.



If they are appointment only that's different and legal.... if they allow walk ins but not PPT's that's not legal.



If the firearm is legally configured they have no legal reason not to.

Snitching to CADOJ is counter productive but blasting dealers who don't follow the laws on Calguns is a good start...

Not during Covid restrictions its not. Local governments have different restrictions regarding how we can or can't operate due to capacity restrictions. Even DOJ has said that complying with local restrictions is OK with them. Complying with these restrictions is what has kept us open for business.

[ronlglock]

Dealers lose money on every PPT but we do them because it is good for the community. However, we are booking 3 weeks out now so when a customer does a DROS, they need to wait up to 3 weeks to pick it up. One customer called our corporate office to complain about that.

Sorry, but we are insanely busy!

[G.O.D.]

Usually I find something I NEED at the Dealer, whether I am the Buyer or Seller.

[BONECUTTER]

Not during Covid restrictions its not. Local governments have different restrictions regarding how we can or can't operate due to capacity restrictions. Even DOJ has said that complying with local restrictions is OK with them. Complying with these restrictions is what has kept us open for business.

What did I say?

If your open for walk in's, even at limited capacity you have to be open for PPTs
If you are Appointment Based...you have to book PPT's as well.
You can't says PPT's are only on these days.
You can't refuse PPT's because they are off roster.

I doubt any local ordnances give dealers the right to snub PPT transactions.

Even if the City says you can only have 1 person in your store at a time they can alternate for the paperwork,

If someone blasts your store on calguns and you have a legitimate argument it should be easy to explain.

[brogrammer]

Dealers lose money on every PPT but we do them because it is good for the community. However, we are booking 3 weeks out now so when a customer does a DROS, they need to wait up to 3 weeks to pick it up. One customer called our corporate office to complain about that.

Sorry, but we are insanely busy!

I kind of assumed this - when you add up the time it takes an employee to work with the customer, to fill out paperwork, and check it. For $10, I was honestly FFLs were doing them until I read it was mandatory for the licensee.

Leaving aside COVID "capacity limits" employees must be "certified" to help complete DROS applications? Correct? I was reading about issues with getting enough employees during a pandemic due to slow turn-around from State on certifying those to sell ammo? Or Guns? Or both?

[ronlglock]

Leaving aside COVID "capacity limits" employees must be "certified" to help complete DROS applications? Correct? I was reading about issues with getting enough employees during a pandemic due to slow turn-around from State on certifying those to sell ammo? Or Guns? Or both?

To perform a DROS - firearm or ammo - employees need to have a COE. To issue FSC they must be a DOJ firearms instructor. Yeah... time and money. In my case I had my FFL03/COE and was a DOJ Instructor for my consulting biz so I could be onboarded in a couple of days. Now I'm sure it would take weeks due to CA backlogs even with all the proper licenses.

[brogrammer]

To perform a DROS - firearm or ammo - employees need to have a COE. To issue FSC they must be a DOJ firearms instructor.

Thank you for this info- adding above.

[Hateca]

You can cry all you want to DOJ about a dealer not doing or limiting PPT but DOJ isn’t going to do squat, especially during COVID. Even without COVID a dealer not doing PPT only benefits DOJ.

[I Swan]

FFL's can cry about PPT as well... I agree DOJ generally does little to nothing about PPT refusals or overcharging but over the years here and there I've seen various FFL's get punished for it.

B&B guns and I think Old West in Santa Barbara are two that come to mind.

[ugimports]

FFL's can cry about PPT as well... I agree DOJ generally does little to nothing about PPT refusals or overcharging but over the years here and there I've seen various FFL's get punished for it.

B&B guns and I think Old West in Santa Barbara are two that come to mind.

Any idea what the penalty was for those 2 shops? I'm curious what the actual "penalty" was or if it was just a note saying "you have to do these".

[taperxz]

What did I say?

If your open for walk in's, even at limited capacity you have to be open for PPTs
If you are Appointment Based...you have to book PPT's as well.
You can't says PPT's are only on these days.
You can't refuse PPT's because they are off roster.

I doubt any local ordnances give dealers the right to snub PPT transactions.

Even if the City says you can only have 1 person in your store at a time they can alternate for the paperwork,

If someone blasts your store on calguns and you have a legitimate argument it should be easy to explain.

You are wrong. If only one person is allowed in the store you don’t have to do them (this has nothing to do with us) The store has a right to operate the way it wishes. For instance, if a person who is not allowed in the store for past behavior, you can refuse service.
If the store requires both parties present, you can refuse the ppt if only one shows at a time. If the buyer doesn’t have ALL paperwork present at time of DROS, you can refuse service. If the buyer doesn’t have an FSC, you can refuse service. FFLs aren’t required by law to administer the test. There are various store policies that allow a store to not do a PPT as long as those policies are consistent.
Small example: If a seller brings a gun in a case but won’t leave a case and the buyer won’t buy a case, we refuse service. We won’t store a gun for 10 days on metal racks with loose guns. I’m not going to be responsible for an accidental scratch. Yes! People have tried and refused to buy a case. This is just a small example of store policy and there are others.

The government cam make laws and regulations but they can’t dictate to an owner what business policies or best practice ideas for company health. Perfectly legit to make a PPT wait while paying customers are taken care of. You didn’t refuse the PPT. I’m not saying this is the BEST practice but it’s just an example of the State not dictating how you do business.

There’s a reason that there’s virtually no penalty for a PPT complaint. The state isn’t going to go to court over how a business decides to run their business. They can make things difficult but it’s not a high priority issue.

Again, these may not be our policies but after consulting a lawyer and our rep at DOJ, you can still enforce store policies when dealing with PPTs.