By John Brown
For those of you who looked for my article last month I apologize for the omission. Some personal matters arose that needed my complete attention and there just wasn’t time to finish my article before the issue went to press.
Just about the time that you think that you have some extra time on your hands, you answer the door and there stand two people you don’t know. One has on smartly pressed 5.11 pants and a polo shirt that you look at for a moment before your heart sinks to your feet. Your senses tell you that these people, who aren’t really smiling the way you would expect, are from the government. All of a sudden a beautiful blue shield nicely cased in a wallet appears with the appropriate government ID and they introduce themselves as Industry Operations Inspectors from ATF. Now your heart, which just sank to your feet, has stopped and you can’t catch your breath. You try not to show it but you know in your head that the panic has set in. You have been waiting for this moment for perhaps years and it’s finally here. The rush of emotions that you will feel at that very moment is indescribable.
You have lain awake at night waiting for this moment for ten years and it is finally here, but you’re never really ready for the shock and awe that hits your body, your brain, and your overall being. You think you’re going to pass out but you know that would not be cool. The inspectors might think you are already guilty of something and that’s the last thing you want them to think. So, you take a deep breath, smile and ask them to come on in. You want to tell them something that will delay this inevitable process, like your dog died, and you have to go to his funeral, but you know in your heart that that will only put off what you have been waiting for and cause you to lose even more sleep. Sounds awful but that is the gut wrenching feeling you get, no matter how well you are prepared for an ATF inspection.
I have had my FFL for over thirty years and no matter how hard you try and prepare for an audit there is nothing you can do to get rid of the jitters during the first few minutes of this introduction. My advice is simple: relax, be a good listener, and let the Inspectors do their work. They have done this work hundreds of times and know what they have been trained to do. Trying to steer their process in any other direction is going to lengthen the inspection and likely delay your time in getting back to running your business. It may not feel this way sometimes but Inspectors don’t want to spend any more time in your shop or your home than the time that you likewise want them there. They want to do their job, have a closing conference with you, and move on. They would prefer to get in and get out. They know and appreciate the fact that you have a business to run and that dragging out an inspection will simply interfere with normal operations, so let them lead the way, do their job and get on their way. You doing a lot of talking out of pure nervousness is simply going to lengthen their stay. Once again, keep your mouth shut, be a good listener, and let them do their job.
Like many FFLs in the country, not having an inspection for long periods of time is not unusual. Some FFLs have not had an inspection in as long as 20 years. The unfortunate side effect of this kind of timeline is that your inspection is going to last longer than you might expect. That process, of experiencing long periods between inspections, is rapidly changing and Directors of Industry Operations (DIOs) have been pushing their Inspectors to tighten up this timeline and in many cases perform at least one inspection every three years. I know, the wait is simply killing you. There is not an FFL in the country that is not preoccupied by the thought process that revolves around, “when are they going to show up?” The answer is simple, you just don’t know. The only thing you can bet on is they will show up, eventually. The good news for many of you is that if ATF does perform more frequent inspections then there is less to look over and you have already been through enough information to continue to polish your operation and be ready for the next inspection.
No matter how short or long an inspection may be you can bet on one simple thing: you will do everything in your power to be 100% in compliance and make certain that you don’t have any trouble, hence the ATF weight loss plan. In a recent inspection, one of our members tells us of losing eight pounds in a week, simply as a result of putting in the extra effort to make certain that all of the work surrounding his compliance was in total excellence. The result of the loss was working all day long with the inspectors and then staying up half the night to make certain that the next day went flawlessly. The amount of time and energy that you are willing to put into an audit is incredible, especially when you want things to go well. The work can be exhausting if for no other reason to make certain that you have checked all of your work at least a half a dozen times. It is a natural tendency for most FFLs to try and stay ahead of the inspection. The time and the effort will generally reward you and your examiners, in the amount of work that is required to complete an inspection.
During the next few articles we want to provide you with as much information as possible to make life easier during an inspection. We will start out with the simple issues and move into the more complex examples of things you must be prepared to deal with. As a primer to this process we will also keep you informed on the professionals in the field that are available to assist you, if in fact you want additional oversight in what you are doing in your compliance process. To ease into this process let’s start with step number one.
Being prepared for an inspection is basically a simple process. You must know your numbers and know them well. The best example that will get you on the right track is a simple count. The number of Title one and NFA items that can be counted in your inventory must match the open entries in your bound book. That is a simple process. If you have 50 guns on your shelves that would simply mean that you have that many open entries in your bound book. This is a simple inventory reconciliation process that shows that you have a matching number of entries to available inventory. This is the first level of initiating your “count.” Obviously, the detail to the count is to insure that every open entry in your bound book matches an item that you have physically in your available inventory. This may sound like a simple process but in fact it can be very complex. If you have a large retail store you may be dealing with an ever increasing turnover of inventory and every changing bound book that must, in the end, match. The obvious detail beyond the count is to insure that every entry in that bound book can be accounted for on the shelf. This is where the tough work begins, making certain that not only the raw numbers match, but so do serial numbers - making certain that you have a one to one match of what you say you have. Make no mistake about it, ATF does and will expect a 100% compliance check on your inventory versus your bound book. Keeping up with that process is one of the principle responsibilities that an FFL has in keeping your records. Making certain that you check for 100% accuracy in your inventory will all but make an Inspector’s job faster and more efficient.
Consider the raw count the first step in your own self compliance check. In follow-on articles we will take you into the depths of what to expect next and the specifics of what you can expect and how to prepare. This is where the real fun begins in preparing for the “real deal.” We want to give you as much information as possible to help alleviate some of the fear in an inspection.
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This article first appeared in Small Arms Review SAW (April 2012) |
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