Keeping your FFL Bound Book accurate is an absolute must. The ATF takes Bound Book violations very seriously. Getting an FFL isn’t that hard, but keeping it can be a challenge.
Most violations come from 4473 mistakes
Yes, ATF Form 4473 is critical, too (most violations come from 4473 mistakes), but if you think of your FFL like a solar system, your FFL bound books are the sun. Everything else orbits around FFL bound books. Every FFL will acquire and probably dispose of at least one firearm. But, not every FFL will transfer a firearm to a non-licensee (someone without an FFL) on a 4473.
The ATF’s primary concern is being able to trace a firearm used in a crime. Theses traces start with the manufacturer and continue down to distributors, dealers, and the end-user. When the ATF calls to trace a firearm, you will rely on your FFL bound book. If transferred to a non-FFL, you would also use the Form 4473. The ATF will want to know 1) whom the firearm was acquired from, and 2) whom it was disposed to.
Get compliant or stay compliant with ATF rules and regulations
If you’re reading this, you likely have an FFL and are looking to learn how to get compliant or stay compliant with ATF rules and regulations. Let’s cover some of what’s required.
As an FFL, whether you’re a dealer, manufacturer, or importer, you must acquire and dispose of firearms within a certain timeframe and in a specific format prescribed by the ATF in your FFL bound book. If you’d like an up-to-date copy of all of the firearms rules and regulations, you might want to pick up a copy of the Federal Firearms Regulations Reference Guide.
You must enter the information precisely as marked on the firearm. After all, that is the information law enforcement will use to trace the firearm – they won’t have the box, invoice, or marketing materials. Requirements are different if the firearm is imported.
What Must An FFL Bound Book Have?
The firearm acquisition information in your bound book must include:
- Manufacturer
- Importer (if any)
- Country of Manufacture (only required for certain FFL types)
- Model
- Serial Number
- Type
- Caliber or Gauge
- Date Acquired
- Name and address of individual received from OR name and FFL Number of FFL if it was a transfer in from another FFL (if you made it, then your info goes here)
The disposition information in your FFL Bound Book must include:
- Date disposed
- Name of who disposed to
- If another FFL, then the address or FFL number of the FFL. If an individual (non-FFL), then their address or 4473 file number if you file your 4473s numerically.
Electronic bound book software for your A&D records save a ton of time
Depending on the type of acquisition or disposition, bound book entries must be made within a certain number of days. Yes, inspectors look at this very closely. The date is the actual date you acquired or disposed of the firearm, not the date that you made the record. Mistakes happen, and it’s better that you correct it. Corrections need to be made in a particular way to remain compliant. Paper records are perfectly legal, but as you can imagine, using electronic bound book software for your A&D records save a ton of time and allow for much more accurate records.
What happens if you don’t interpret the answer correctly?
The White Book, as it’s called, is about two inches of CFRs (Code of Federal Regulations) that are provided by the ATF and cover the basics in detail. You can always call the ATF and ask questions. That is not in writing, and what happens if you don’t interpret the answer correctly? But how do you remember all of those rules and regulations that seem to be ever-changing? You can phone a friend if you happen to have a credible ATF FFL expert on speed dial. Calling an attorney that specializes in ATF and FFL matters is another option.
This may read like a shameless plug, but this is our personal experience. We reached out to an attorney once, who specialized in ATF issues, and their best solution was to put up a $50,000 retainer to sue the ATF! We quickly realized that their interests might not necessarily be aligned with ours. Right after this is when we found the FFL legal and compliance experts at FFLGuard. Their prior expertise in dealing with the ATF resolved our issue, in writing, for a flat fee. Sure, we could have canceled before the end of the month, but the peace of mind we get from having their legal and compliance experts on call is invaluable. We’ve been a happy client for years.
Follow The CFRs, and/or Rulings, and/or Clarification Emails
You might be surprised that the ATF doesn’t certify or validate software used by FFLs, burdening you with finding software that meets all of the requirements, has a proven track record of updating the software when things change, and provides some sort of assurance that the software is compliant besides “we’ve never had a problem” or “so-and-so endorses us”. First, spreadsheets were prohibited. Then Spreadsheets were allowed, but only with requirements that aren’t possible in Excel or Google Sheets. As with most things these days, technology can automate mundane tasks for you–like hand-writing thousand of lines in a paper book every year.
Make Your Life Easier
If this whole thing seems daunting, you’re right. It is an essential part of holding a Federal Firearms License. FastBound is the largest provider of FFL Bound Book Software. Unlike our competitors, we don’t own a gun store, looking to make some extra money on the side. Our entire company has been dedicated to firearms compliance software, and only that since 2010.