Submitting C&R with Modern Firearm - Recording of FSC or Other Exemption

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EDIT: I did a test and started with modern firearms first, and that seems to be a valid method as the FSC/Exemption part is covered and does not affect the C&R transaction. This seems to be an issue when starting with the C&R firearms.


Hi Folks,

Since DES locks the buyer info when adding multiple firearms transactions to the cart... When doing mixed transactions with C&R and modern firearms how do you log the FSC number or other exemption to the modern firearm(s) transaction(s)?

1. The proper way seems to be submit C&R separate from modern transactions but then the buyer is charged multiple DROS fees.

2. The alternative seems to be to continue with the transaction and note the FSC or other exemption in the notes even though we know DES staff doesn't generally read the notes. The buyer is only charged a single DROS fee here but would the FFL be at risk of an administrative error?

Yes, this is DOJ's fault. I also noticed that we can use hyphens in the FSC and DES fields now. I look forward to transactions getting rejected. *Sigh*

Seeking experiences here before reaching out to DES staff. Thanks

[Nardo1895]

I'm assuming the buyer has a C&R+COE. If not then you have to enter the FSC on all transactions.

The FSC C&R Exemption works for modern firearms, not just C&R firearms. Its the person that is exempt, not the firearm (unlike the 10 day wait exemption which is both).

When running multiple purchases I start with the C&R(s) to make sure I don't trip the 1 in 30. I'm not positive starting with the modern would trip 1 in 30 but I know it does if the transactions are on separate DROS.

Also, if the buyer has a FSC, which appears to be the case in your example, you can always enter it on the C&R transaction. There is no requirement to use the C&R exemption if you have a FSC.

[Quiet]

The FSC C&R Exemption works for modern firearms, not just C&R firearms. Its the person that is exempt, not the firearm (unlike the 10 day wait exemption which is both).

The C&R FSC exemption only applies to C&R firearms. [PC 31700(a)(6)]



Penal Code 31700
(a) The following persons, properly identified, are exempted from the firearm safety certificate requirement in subdivision (a) of Section 31615:
(6) A federally licensed collector who is acquiring or being loaned a firearm that is a curio or relic, as defined in Section 478.11 of Title 27 of the Code of Federal Regulations, who has a current certificate of eligibility issued by the department pursuant to Section 26710.

[Nardo1895]

The C&R FSC exemption only applies to C&R firearms. [PC 31700(a)(6)]



Penal Code 31700
(a) The following persons, properly identified, are exempted from the firearm safety certificate requirement in subdivision (a) of Section 31615:
(6) A federally licensed collector who is acquiring or being loaned a firearm that is a curio or relic, as defined in Section 478.11 of Title 27 of the Code of Federal Regulations, who has a current certificate of eligibility issued by the department pursuant to Section 26710.

Hard to argue with the code reference but the exemption shows up in DROS even if you run a Regular Dealer Transfer.

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Hard to argue with the code reference but the exemption shows up in DROS even if you run a Regular Dealer Transfer.

Doesn't mean it's the correct way despite DOJ staff allowing the transactions to go through even if you selected (it's manual process). The point is the FSC must be recorded for the modern firearm, and it's a matter of how to do it in this scenario.