FFL-03 Renewal Question

[G. Freeman]

Hi Folks,

This is my 1st time renewing my 03. Just could use some direction:

1. I purchased a couple of modern pistols (on roster, non-C&R), using my COE and FFL-03 in order to get exempted from the 1-30 day rule. Of course, still went through the proper transfer and waiting period via an FFL-01.

Do I enter this in my logbook and report this on the renewal form?

2. Would you have a link to any free PDF that I can use for my log?

Thanks so much in advance!

[acespawnshop]

NOT an 03 FFL. We are a retailer. But let me take a crack at this question. Remember this advice is what you're paying for it.

Q1: I doubt it, you didn't really use your 03 as intended by ATF to acquire these guns so I doubt you would need to log these into your book.

Q2: Amazon sells one for $19 I think that works great for us. But probably overkill for an 03 FFL. You can make your own up if you want to also, just include all the same fields that would be required by the ATF to meet the standards of a bound book. Use google images of the book and copy from there if you want to do it in Word or something, make your own and fill it in as you go.

EDIT: I should have said use Excel not word for creating your own book. My bad.

[Nardo1895]

Q1 is a point of contention for some. Some say everything goes in your A&D Book, others say only C&Rs you acquire using your 03. I think if you read the ATF guidance it at least implies everything. But that doesn't make much sense to me.

Brownells has an A&D book for something like $6. I don't use them for my 01 because the spaces are rather small, but they would work fine for an 03.

You should post Q1 on the C&R forum. I think you'll get more responses there.

[SVT-40]

There is no point of contention.

The regulations state that while you are a licensed collector, all curio & relic firearms you acquire or dispose of must be entered into your bound book.

Nothing else gets entered.

No modern or antique (pre 1898) or black powder firearms.

Thats it.

[19K]

Q1 is a point of contention for some. Some say everything goes in your A&D Book, others say only C&Rs you acquire using your 03. I think if you read the ATF guidance it at least implies everything. But that doesn't make much sense to me.

Brownells has an A&D book for something like $6. I don't use them for my 01 because the spaces are rather small, but they would work fine for an 03.
You should post Q1 on the C&R forum. I think you'll get more responses there.

What point of contention? It’s black and white.

The regulation at 27 CFR 478.125(e) requires a licensed dealer to record, no later than the close of the next business day following the date a firearm was received, the date of receipt, name and address or the name and license number of the person from whom the firearm was received, name of the manufacturer and importer (if any), model, serial number, type, and caliber or gauge. This section further requires a dealer to record the disposition of firearms showing the date of sale or other disposition, and the name and address or the name and license number (if a licensee) of the person to whom the firearm was transferred. This information must be entered not later than seven days following the date of such transaction, and must be maintained in bound form under the format prescribed by 27 CFR 478.125(e).

Additionally, 27 CFR 478.125(f) requires a licensed collector to record, not later than the close of the next business day following the date of purchase or other acquisition of a curio or relic, the date of receipt, the name and address or the name and license number of the person from whom the curio or relic was received, the name of the manufacturer and importer (if any), the model, serial number, type, and the caliber or gauge of the firearm curio or relic. This section further requires a collector to record the date of the sale or other disposition of each firearm curio or relic, the name and address of the person to whom the firearm curio or relic is transferred, or the name and license number of the person to whom transferred if such person is a licensee, and the date of birth of the transferee if other than a licensee. This information must be entered not later than seven days following the date of such transaction, and must be maintained in bound form under the format prescribed by 27 CFR 478.125(f).


And here is the regulation

https://www.law.cornell.edu/cfr/text/27/478.125

regulation at 27 CFR 478.125(e) Applies to licensed DEALERS.

Are 03 holders dealers? No. They are collectors. So they are not subject to section (e). There is a specific regulation (f) in which licensed COLLECTORS are subject to. You are only required to list any C&R firearms that are acquired during the time that you are a licensed collector.