Education for new (and old) counter persons

[Librarian]

I tried to get an education program going a few years ago, with an organization off the forum, but it never went anywhere.

I had thought of it as a small booklet of simplified practice of CA and Federal law for FFL employees - with a test. Perhaps such a thing might reduce the incidence of errors told to customers.

Any interest in the project?

[ronlglock]

Education for new (and old) counter persons

+1 and I write for Police1 so I am willing to help write and produce.

[Elite Armory]

Yes, very interested!

[????? ????]

[taperxz]

I will help if I can.

[Librarian]

Support! I like it.

Let me write the preliminary scope as I see it, as the first step.

First, I am not an FFL, nor do I run a business, so I would try to avoid some details there; please feel free to be critical and corrective should I say anything goofy. Real FFLs should share business practices with each other and employees, but I think that's mostly out of scope for this project.

1) There is, of course, a lot of law and regulation:

- Federal law
- California law
- occasionally county or city law.

2) Then, there are interpretations of those laws, including

- you/your business's lawyer
- BATF official statements
- CA-DOJ official statements
- BATF inspectors
- CA-DOJ inspectors
- possible city/county inspectors

3) And then, there is the way you want to run your business to make money.

I suggest the scope here ought to be to provide 'why are we doing this?' information out of (1) and some of (2), in enough detail that it's harder to unknowingly do or fail to do something(s) that would fail an audit.

I think the product here should be something like a PDF one could print and hand to an employee.

Discussion ...

[????? ????]

[Elite Armory]

I think 1 and 2 would be great. 3 is pretty subjective. It's like trying to answer what the best way to run the country would be. There are a thousand ways to solve this puzzle correctly.

I assume the idea is to create some form of best practices checklist for each kind of transaction, particularly for some of the less ordinary transactions such as immediate release of a C&R firearm, or interstate intrafamilal transaction.

I assume this will do two things. One, it creates some sort of uniformity so that a customer can actually expect certain things when going to a local gun store instead of encountering the “well, it depends on which FFL you go to” and “find a better FFL.” It really sucks when rights are dependent upon which clerk is at the counter. The variety of what is considered acceptable identification documents is aggravating to me.

Two, I hope it takes some pressure off gun store owners and their insurers. A lot of practices at gun stores are not because it’s what’s legally required, but because of the fear of being sued or the fear of being investigated by CA DOJ and ATF. So it becomes easier to just decline to do certain things instead of creating any risk. If there’s a document of well-established and well-sourced best practices, I think everyone, even DOJ Bureau of Firearms, would appreciate it as something that can be relied on. And it might cause gun store owners to be less afraid of the less ordinary transactions.

I think fear of not doing something correctly is only part of this inconsistency you see. With common things I can see that but when you talk about off things like immediate C&R release, people with visas purchasing firearms and other stuff that are not everyday occurrences, I think a lot of FFL's are busy enough with easy transactions than to try dig up answers on more difficult transactions so instead of doing an hour worth of work to make one transaction, it's easier to do 20 minutes worth of work for the same transaction. This book may help eleviate this if it is thorough enough but if it is too thorough then it becomes too big and too much to take in. I'm curious to see what you guys come up with.

[Librarian]

I think 1 and 2 would be great. 3 is pretty subjective. It's like trying to answer what the best way to run the country would be. There are a thousand ways to solve this puzzle correctly.



I think fear of not doing something correctly is only part of this inconsistency you see. With common things I can see that but when you talk about off things like immediate C&R release, people with visas purchasing firearms and other stuff that are not everyday occurrences, I think a lot of FFL's are busy enough with easy transactions than to try dig up answers on more difficult transactions so instead of doing an hour worth of work to make one transaction, it's easier to do 20 minutes worth of work for the same transaction. This book may help eleviate this if it is thorough enough but if it is too thorough then it becomes too big and too much to take in. I'm curious to see what you guys come up with.

Book? Bigger than a poster or a tri-fold, but pamphlet, at most. Maybe 10 sheets, 8 1/2 x 11. Too big is surely tl;dr.

CD Michel has the book thing covered - https://www.calgunlawsbook.com/ 8th edition is $30 from Amazon. Worth it, if you have time to read and absorb it.

I don't think 'A CA FFL's Handbook of Business Practices' is where I would be going. You're right - too many ways to make (or lose) money, so while employees do have to know a lot of that, the most I'd like to see on the (3) stuff is something along the lines of 'Yes, we know the law, but where there is some wiggle room, we follow our own procedures because They Make Us Happier.'

Example: a recent post here reported that an FFL told a customer that a shipment of a gun must, by law, come from an FFL. That's incorrect. I'd like FFLs to confidently state 'That is our policy' and avoid mis-statements of law, even if those can deflect customer complaints to the 'higher power'. (Yes, in other contexts I've done similar things - sometimes it's simpler and faster when there are more things to be done).

But again, that's an area (3) thing, really outside my competence.

BTW, is there a DES manual for DROS transactions, and if so is it any good? There used to be one I could get at, years ago.

[morrcarr67]

For me as a consumer I'd to see you discuss C&R firearms and C&R FFL. Of course you would need to add in content about the COE as that brings up several exemptions, both for C&R firearms and non C&R firearms.

I've had dealers tell me that a C&R needs to made before 1898.
I've had dealers tell me that if it's not listed in the "brown book" it's not C&R.
I've had dealers tell me that if it's a pistol it has to be 50 years old or older to be "considered" C&R in CA.
I've had dealers tell me that if it shoots a modern cartridge it doesn't qualify as C&R.

I'm sure there's more that I'm missing but this is what comes to mind. It would also be nice to touch on how to identify the age of a firearm. Mention the use of websites and books that can be used to age firearms on the spot.

The last thing I'd like, but not sure that it would fall into the scope of what you're doing is to touch on the fact that the CA DOJ left out a release for PPT of C&R firearms to 03 FFL's with a COE. I am pretty sure there are a couple of work arounds, add it to inventory and call the DOJ (so I've heard). Yet many dealers either don't know this or are not willing to do this. Any help in this would be great.

[morrcarr67]

Another thing that just popped into my head is how to enter in firearms with no serial numbers. I've seen that asked in this subsection before.

[Nardo1895]

BTW, is there a DES manual for DROS transactions, and if so is it any good? There used to be one I could get at, years ago.

This?

https://oag.ca.gov/sites/all/files/agweb/pdfs/firearms/pdf/dros-des-firearms-ammunition-dealer-user-guide.pdf

[taperxz]

Book? Bigger than a poster or a tri-fold, but pamphlet, at most. Maybe 10 sheets, 8 1/2 x 11. Too big is surely tl;dr.

CD Michel has the book thing covered - https://www.calgunlawsbook.com/ 8th edition is $30 from Amazon. Worth it, if you have time to read and absorb it.

I don't think 'A CA FFL's Handbook of Business Practices' is where I would be going. You're right - too many ways to make (or lose) money, so while employees do have to know a lot of that, the most I'd like to see on the (3) stuff is something along the lines of 'Yes, we know the law, but where there is some wiggle room, we follow our own procedures because They Make Us Happier.'

Example: a recent post here reported that an FFL told a customer that a shipment of a gun must, by law, come from an FFL. That's incorrect. I'd like FFLs to confidently state 'That is our policy' and avoid mis-statements of law, even if those can deflect customer complaints to the 'higher power'. (Yes, in other contexts I've done similar things - sometimes it's simpler and faster when there are more things to be done).

But again, that's an area (3) thing, really outside my competence.

BTW, is there a DES manual for DROS transactions, and if so is it any good? There used to be one I could get at, years ago.

[Tyke8319]

Much of what all of you suggest is sound...in theory. The down side is, how do you get around experienced guidance from thos of us in the business when confronted with a legal entity (DOJ/ATF) that says "your wrong, do it this way".
I've had an ATF field agent tell me at the SHOT Show exactly what MORRCAFF67 noted about "anything that shoots modern ammunition doesn't qualify as a C&R". And, DOJ advising ,"short barrelled rifles even though listed in ATF FIREARMS, CURIOS OR RELICS are illegal CA.
How do you lay out "procedure" only to have it, potentially, erroneously nullified?

Or am I missing the point here....?

[Tyke8319]

All else said, I'd be very interested.