COE + C&R 1 in 30 Modern SSE Handgun(s) DROS

[NiteQwill]

I plan on buying two (2) new SSE'd handguns at the same time. I have the required COE + C&R paperwork. I just wanted to make sure a DROS doesn't get kicked back, denied or flagged by CADOJ.

A FFL I'm dealing with is very open to what I've shown them regarding the PC. So they are willing to do the 1 in 30 exemption, possibly showing them the process... but I want to make sure there are no mistakes.

Are these steps correct for the FFL dealer for BOTH guns?

• Select Exempt Handgun Sale link.
• 30-Day Restriction Exemption - YES
• Comments - C&R FFL# blah-123-blah, COE# 12345
• Fill out the rest of the DROS info as normal for SSE guns...
• Repeat for gun 2.
• Keep copies of C&R + COE on file.

Thanks!

[kemasa]

Personally, I would not put the C&R FFL number in the comment field since that will raise the issue. The CA DOJ does not like that it exempts modern handguns. Nothing needs to be put there.

[NiteQwill]

Personally, I would not put the C&R FFL number in the comment field since that will raise the issue. The CA DOJ does not like that it exempts modern handguns. Nothing needs to be put there.

So, leave the comment field BLANK?

Otherwise, the rest is good to go?

[kemasa]

Yes, that is my suggestion. Everything else looks fine.

The FFL should have reference to the CA PC as being exempt to CA PC 27535, specifically (b)(9). If you look at the CA DOJ FAQ, it says that the exemption is only for C&R, but the CA PC does not say that:

27535. (a) No person shall make an application to purchase more
than one handgun within any 30-day period.
(b) Subdivision (a) shall not apply to any of the following:
...
(9) Any person who is licensed as a collector pursuant to Chapter
44 (commencing with Section 921) of Title 18 of the United States
Code and the regulations issued pursuant thereto, and has a current
certificate of eligibility issued by the Department of Justice
pursuant to Article 1 (commencing with Section 26700) of Chapter 2.
...

Part of the problem is that the CA DOJ talked to some people at the BATF in Sacramento (I think that is the office) and was given incorrect information regarding the "use" of a C&R FFL. Having a C&R FFL and therefore qualifying for the exemption is not "using" the FFL since you are not logging anything with the C&R FFL. For example, if I were to give a discount for people who have orange shirts, they are not actually using the orange shirt when they get the discount, they just happen to have it and happen to get the discount. If the CA DOJ were to talk to others at the BATF, then the answer would change.