By John Brown
For those of you who had the opportunity to read our last article welcome back. For those of you who missed the last article, our objective is to help tame the fears of an ATF compliance inspection by providing you with enough information so that you are well prepared for an inspection. In our last article we detailed what we call the “Raw Count” or the actual comparison of inventory on hand compared to your open entries in your bound book. The raw count is simply making certain that what you have on hand for sale matches what you have in your bound book. In simple terms, if you have 150 open entries in your bound book, then you had better have that many articles that you can account for in your shop. With ATF policy requiring inspectors to apply 100% compliance standards to any inspection, that will mean that you are likely to see the inspector check every serial number you have on hand to make certain that a corresponding entry is in your bound book. For those of you that have NFA items this raw count will also apply to that inventory. For every open entry in your records, that serial number must be accounted for in the count. As we will explore in part III, reconciling your NFA inventory can be a rather arduous process, especially when you are looking at the printouts from the National Firearms Registry and Transaction Record. We will deal with that one later.
So let’s assume that your raw count is complete and in your double checking to find out why you have more guns than you have in your open entries. You realize that after staying up half the night double checking everything you have finally reconciled the numbers and everything has been found. It was a long day and when you go to bed that night you realize that you have lost about 5 pounds because you didn’t eat and have continued on your fast until you can reconcile everything. The weight loss plan will continue its successful journey because now you are going to toss and turn all night long just trying to figure out, what’s next? Now starts day two of the ATF weight loss plan.
Assuming that you have done some sort of inventory in the last year you figure that you can now move on with the inspectors to other things. What happens next is a thorough examination of all of your forms, especially your federal 4473s. I have always been told that you must have someone other than yourself look through your 4473s. This is great advice and I would encourage you to have anyone aside from yourself look through your 4473s and any State forms that may be required in your state. A lot of things can happen to you in looking over your 4473s but your worst enemy is the old expression “familiarity breeds content.” If you are like me and have been looking over these forms for over 30 years you absolutely must have someone else monitor the quality of your forms. Any mistakes on a 4473 can be a written violation. It was not until my most recent inspection, in the closing conference, the inspector spent about ten minutes explaining how critical the 4473 accuracy was a legal instrument. That conversation had a huge impact on my closing conference. The moral to this story is, always have someone else review your work. No matter how good you think you are, I will guarantee an independent eye can catch your oversights. If the same person looks over the same forms they supervised being filled out and monitors that process for quality control, you are bound to make a mistake sooner or later. Keep in mind, once again, that this will be a 100% compliance inspection and every single 4473 will be scrutinized in your compliance inspection. We have now made it a policy to have someone else recheck every single 4473 at the end of every business day. At the end of every month they are checked again for quality control. No matter how hard you try you will still inadvertently make a mistake. Have someone else perform your quality check to insure that you are 100% compliant, especially if you are manually handling your 4473s.
If you are keeping your 4473s as a manual process I would heartily recommend that you consider the eForm 4473 available from ATF. The program is easy to download and is available at www.atf.gov/applications/e4473/. The good news with this process is that you can’t move through the form without completing every step required. You will still be keeping a paper copy of your 4473 but the program, as designed, makes it nearly impossible for you to make a mistake. So at this point you ask yourself, what are the advantages of using the eForm 4473? The answer is simple and already provided on the ATF website:
Q: What are the advantages to filing Form 4473s electronically?
- Eliminate or reduce possible clerical errors
- Eliminate or reduce blanks or omissions on the form
- Flag seller if buyer has indicated he/she may be prohibited
- Answers will be legibly printed
- Ease in filling out the form (for example, when the buyer lists their ZIP Code, the city, State, and county (if applicable) can be automatically populated)
The application is free to any FFL and is an almost sure-fire method of eliminating the common mistakes in the manual process. So step II in your compliance program is making it through the inspection of your 4473s. Unfortunately, this process too may be grueling, especially when you think that just because you have reviewed everything yourself, you just are absolutely certain they are all correct. Again in many cases this is not the way things pan out. Study all of your 4473s and get help in monitoring your quality process.
Once again you are now finished with the examination of your 4473s. You came in early to double check them and now this portion of your inspection is finished. But hold on, you’re far from being finished.
In the next article or The ATF Weight Loss Plan: Part III, we will explore how to make your NFA portion of your inspection less painful than it can be. For this portion of your inspection you’re going to need to understand the many tools that your inspector will be working with in this review.
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This article first appeared in Small Arms Review SAW (May 2012) |
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