07 FFL question...before I seal this envelope.

[guns4life]

Setting up my 07 to manufacture ammo(firearms as we expand operations). I've got my wholesale permit, paid the business tax and cleared with the landlord. I have my complete app ready to go, however I noticed today on the DOJ website that they require....

A regulatory or business license that states on its face, "Valid for Retail Sales of Firearms" and endorsed by the signature of the issuing authority; or...

and

In the form prescribed by the Attorney General;

?

My question is as a wholesaler, is there going to be a problem here? This is my first venture into wholesale, it seemed appropriate given the volume we plan to produce. Also, will being a wholesaler effect my ability to sell to the general public if I decide to go that route as well(gun shows, web, etc)? Also, what is that other option there? If I need to change to retail I'll need to amend my application as well, right?


My next questions are about the inspections and equipment...

Do I need to have all my equipment in place before the inspections?
Where can I find a listing of other items I will need in place to comply with any codes for this type of business? (per DOJ,OSHA, etc I'm pretty sure I know where to find local requirements).



Thanks!

Feel free to PM me if you'd prefer...I'd also appreciate any other info that may help me out, every tip helps no matter how big or small.

[ParallaxTactical.com]

Yes, you will need to have this done with the city before you even send in the FFL. Otherwise, they will send an letter or an inspector and tell you the same in person.

[franklinarmory]

guns4life, here's whatchya do.

The "Valid for Retail Sales" bit is only if you intend to be firearms DEALER. As a manufacturer, you do not need that unless you also intend to do retail GUN sales. Look under 12085 and 12086 of the penal code. 12071 is for DEALERs while 12085/86 is for MANUFACTURERS. As an 07FFL, you can manufacture to your hearts content, and then when you're ready, call up the state for a DROS account. You won't need a different license from the Feds, but you will have to then have the local license which will have to read "Valid for Retail Sales."

If your zoning does not allow retail sales, one argument to present to you city planning department is that you want to do retail sales at gun shows. This still won't make it legal for you to do retail sales at your business location unless it is a retail site, but it will allow you to do what you want to do.

Think of it like a door to door salesman that does not even have a business address. (e.g. that works out of their home.) They can legally get a retail sales business license from the city even though the don't have a business location. It also helps to inform the planning people to let them know that, by law, the only two places you can sell guns are your FFL address and gun shows. That way they don't think you're selling ammo and guns at Starbucks or something.

Hope that helps!

[guns4life]

guns4life, here's whatchya do.

The "Valid for Retail Sales" bit is only if you intend to be firearms DEALER. As a manufacturer, you do not need that unless you also intend to do retail GUN sales. Look under 12085 and 12086 of the penal code. 12071 is for DEALERs while 12085/86 is for MANUFACTURERS. As an 07FFL, you can manufacture to your hearts content, and then when you're ready, call up the state for a DROS account. You won't need a different license from the Feds, but you will have to then have the local license which will have to read "Valid for Retail Sales."

If your zoning does not allow retail sales, one argument to present to you city planning department is that you want to do retail sales at gun shows. This still won't make it legal for you to do retail sales at your business location unless it is a retail site, but it will allow you to do what you want to do.

Think of it like a door to door salesman that does not even have a business address. (e.g. that works out of their home.) They can legally get a retail sales business license from the city even though the don't have a business location. It also helps to inform the planning people to let them know that, by law, the only two places you can sell guns are your FFL address and gun shows. That way they don't think you're selling ammo and guns at Starbucks or something.

Hope that helps!

Thank you, I called DOJ(minutes before checking this thead in the early afternoon) and they told me I'd need a different license(issued by BATF) if I went wholesale vs retail...exactly what you talked about. To make it easy in the future I just went and changed the tax cert to firearms retail(under sporting goods store) and sporting & athletic goods MFG, I also got my sellers permit under retail.


I've looked at the DOJ website, the only thing I need(at this point) is more building security, which I have already gotten a quote for.



so far I've...

Secured investment capital
Leased building
Cleared zoning
Secured sellers permit
Secured business license
Applied for my COE
Applied for a DOJ instructors cert.
Applied for my 07 FFL
Mailed a copy of my FFL app to the CLEO
Gotten my EIN#

Anything else I'm forgetting to do for the time being?


I have a current 03FFL, I was wondering if that would help the process along??

[franklinarmory]

I didn't see ITAR on your list. You will need to pay the US State Department $2250 per year so they can look up your skirt and see if you have any warts. Basically, they just take your money on an annual basis. Others will disagree with me on this, but the penalty for non-compliance is 8 years in Club Fed... ...no thanks...

You will also need to be licensed as a CFD or CFLC, so you can actually get firearms shipped to you to sell to your customers. If you are manufacturing more than 99 firearms, then you are going to need a State MFG license. If you build more than 499 units, then you need the super-dooper State MFG which costs even more.

Isn't all this government compliance BS fun?!?!?!

[guns4life]

I didn't see ITAR on your list. You will need to pay the US State Department $2250 per year so they can look up your skirt and see if you have any warts. Basically, they just take your money on an annual basis. Others will disagree with me on this, but the penalty for non-compliance is 8 years in Club Fed... ...no thanks...

You will also need to be licensed as a CFD or CFLC, so you can actually get firearms shipped to you to sell to your customers. If you are manufacturing more than 99 firearms, then you are going to need a State MFG license. If you build more than 499 units, then you need the super-dooper State MFG which costs even more.

Isn't all this government compliance BS fun?!?!?!

D'oh! I knew it couldn't be this easy. HAHA!

I'll look into myself, but can you elaborate on CFD(California firearms dealer?) CFLC(no clue on this one, other than california something or rather).


Also, can/should I wait for my FFL and I'm ready to manufacture before I take these steps? I don't mind spending the money(I DO mind it actually) I just don't want to pay too soon and waste it, it could be another year before I actually get all the equipment in and going...optimistically.


Thanks again for your input, the last thing I want to do is accidentally skip a step and get bogged down with delays/penalties/etc.

[franklinarmory]

If you're a "dealer" under state law, you need a CFD #. If you are a mfg, you need a CFLC #, but I think a MFG license (either one) will include the cost of a CFLC #. Yes, don't pay the ITAR if you're not going to do anything with it for a year. Expect them to take 1-3 months to process your request, so plan your manufacturing time lines accordingly.

I don't think that you are allowed to apply for your CFLC until you have your FFL in hand, and I know they won't give you a state MFG license until AFTER you send them your 07/FFL. Tami normally takes about a month to process your applications. (...and when you call her, she has a 2 minute out going message, and her phone only allows YOU to record a 30 second message. ...she's a nice person, but it sucks trying to get a hold of her!)

[guns4life]

If you're a "dealer" under state law, you need a CFD #. If you are a mfg, you need a CFLC #, but I think a MFG license (either one) will include the cost of a CFLC #. Yes, don't pay the ITAR if you're not going to do anything with it for a year. Expect them to take 1-3 months to process your request, so plan your manufacturing time lines accordingly.

I don't think that you are allowed to apply for your CFLC until you have your FFL in hand, and I know they won't give you a state MFG license until AFTER you send them your 07/FFL. Tami normally takes about a month to process your applications. (...and when you call her, she has a 2 minute out going message, and her phone only allows YOU to record a 30 second message. ...she's a nice person, but it sucks trying to get a hold of her!)

I'm going to spend the down time getting the building security up to par...



Thanks again for the help, I owe you one.

[guns4life]

Update:


ATF inspection on Monday.

[EBR Works]

How long after ATF received your application did you receive the call to setup your first meeting with the agent?

[Gunsmithing]

About 5 weeks for me
ATF will tell it take up to 3 months

Dave

How long after ATF received your application did you receive the call to setup your first meeting with the agent?

[guns4life]

How long after ATF received your application did you receive the call to setup your first meeting with the agent?

I was getting worried because almost two months had passed so I called, sure enough my app was nowhere to be found, but my check was cashed. Three days later they called back and had found my app and forwarded it to the local office. It took about 30 days to get the call from the local office(today).

[EBR Works]

Thanks guys. 30 days and waiting here......

[guns4life]

Thanks guys. 30 days and waiting here......

That's only the first wait...next you have to deal with the CA DOJ, that's the tough one from what I've heard.

[EBR Works]

That's only the first wait...next you have to deal with the CA DOJ, that's the tough one from what I've heard.

Any idea of the wait time for this?