DROS thumbprint procedure

[opencarry]

I noticed something that could potentially be blown out of proportion by the ATF and/or DOJ. Some FFLs put the thumbprint on the front of the DROS, some on the back. Isn't it technically illegal to put it on the front? If found this:

http://ag.ca.gov/firearms/dlrfaqs.php#32G

Are firearms dealers required to capture the thumbprint on the DROS form for each firearm recipient?

Yes. The firearms dealer must require the firearm recipient to place his or her right thumbprint, in black ink, on the back of the DROS form. If the recipient is unable to comply, then the dealer should contact the DOJ at (916) 263-4887 for instructions.

(PC section 12077)

Thoughts?

[tenpercentfirearms]

The Penal Code states the back.

The DOJ doesn't really care and might tell you to put it on the back instead of the front or they might just say good enough.

[opencarry]

I always worry that the DOJ will reverse itself, then prosecute people for something stupid like this (i.e. AW registration fiasco that created instant felons).

[scoutpup99]

My doj inspector dinged me on my inspection since it was on the back. She said it is supposed to be on the front even though the P.C. says otherwise.

[tenpercentfirearms]

My doj inspector dinged me on my inspection since it was on the back. She said it is supposed to be on the front even though the P.C. says otherwise.

And there you go. It really doesn't matter I suppose. Either way we are screwed so who cares!!!

Just do it on the back. If you are currently doing it on the front, stop. And starting doing it on the back. If the DOJ dings you for doing it on the front, show them the PC before they finish the write up.

The CA DOJ does not have the resources to prosecute people for the location your thumbprint is at. Second of all, mainly the DOJ actually wants most FFLs to stay in business or they will cease to have a reason to exist.

[ugimports]

And there you go. It really doesn't matter I suppose. Either way we are screwed so who cares!!!

Just do it on the back. If you are currently doing it on the front, stop. And starting doing it on the back. If the DOJ dings you for doing it on the front, show them the PC before they finish the write up.

The CA DOJ does not have the resources to prosecute people for the location your thumbprint is at. Second of all, mainly the DOJ actually wants most FFLs to stay in business or they will cease to have a reason to exist.

THis was basically what I inferred from my inspection as well. If you're doing everything else right they are not going to bust you for the thumbprint. However, just like the stupid 4473 form I think if you are about to get busted than each thumbprint on the front can be a count of screwing up that PC for additional charges.

THe ATF person was telling me the reason for 11a-l is not so much to "catch" bad guys because they will lie.. it's about each question being an additional count of purjury when they do get busted.

[Ubermcoupe]

My FFL put it on back next to my photocopy ID, HSC, & Residency... it wasn't even a good thumbprint but she wanted $22.00 to take a new one... (little DMV humor, heh heh) :'(

[ripro75]

My auditor said the front was fine.

[kemasa]

I have heard that auditors have said that the front is ok, but since the law says to put it on the back why not just put it there and be done with it. The next auditor might know what the law actually says :-).

[slick44]

After my first audit my DOJ field rep asked me to use the front, says he likes it there because it keep him from having to flip the page over to check for the print.

[kemasa]

Ahhh, yes, being lazy is a good reason to not follow the law.

As was said, the next DOJ agent will most likely be different. Get it in writing if they want something else.

[EBR Works]

A local dealer graciously allowed me to spend the day at his location behind the counter to observe how things are done. His process is to place the fingerprint on the front of the DROS form per the request of his DOJ auditor. Two other dealers in my area do the same thing. What's a new guy to do other than to follow by example?

[kemasa]

Following by example can be a bad idea. If you know that the CA PC says to put it on the back, then you put it on the back. If the DOJ agent wants to get the DOJ to send out a letter stating that it is to be put on the front, then you might have something, but it would be better if the DOJ got the law changed so that it just had to be on the DROS.

Do you really want to be in a position where you are saying "but the other DOJ agent said to put it on the front" to a DOJ agent who knows and cares about the actual CA PC, rather than what is easier for them? Do you have it in writing from that DOJ agent? If they are not willing to put it in writing, then that says something.

[EBR Works]

Maybe we need a poll

But seriously, your point is well taken. Thanks.

[Colonel Monk]

Ahhhhh! Zombie Thread, killit killit!

Seriously though - the thumbprint thing - maybe printing front and back is well, makes everyone happy?

I'm kind of a fan of scanning the paperwork into an epacket for backups - not sure how big a deal it is, but if your shop catches on fire and the papers burn up, shouldn't we have a backup of them?

Boss told me to use these special thumbprint stickers. I assume he was asked to do so by his field agent - but then again, we've been putting them on the Driver's Lic copy, so the DROS print requirement was new to him....

Luckily, these thumbprint stickers can be moved from one sheet to the other.

I'd really like to know though if you all are using the stickers or are then unnecessary, and do you see any harm in printing both sides to satisfy both the law, the auditors who like the front page, and ourselves in that front page makes scanning easier.

Thoughts?