Last updated Dec 17, 2024As the newest, and fastest growing, FFL software, there may be questions or concerns about FFLSafe’s compliance with ATF’s rules and regulations.
In this article, we’ll address ATF rules and regs for FFL software and address how FFLSafe meets or exceeds every requirement – we truly believe that FFLSafe is the most compliant software available.
Acquisition and Disposition Record
The ATF requires that all FFL’s keep a log of every firearm in their inventory and from where it came as well as all firearms that have left their inventory (e.g. sale or transfer to another FFL).
This log is called the Acquisition and Disposition Book (or A&D Book) because it contains all of the firearms made or received (acquisitions) and all of the firearms sold, transferred, or destroyed (dispositions).
The ATF requires that certain information is kept in this record in a timely manner.
The Acquisition information requires the following information about each firearm if known: Manufacturer, Importer (if any), Model, Type of firearm (e.g. rifle, shotgun, etc), Serial Number, and Caliber or Gauge. Additionally, the date of acquisition and the source of the firearm must be recorded and include either the person’s name and address or the FFL’s name and license number.
Acquisition and Disposition Records can either be paper or electronic and must be kept for the life of the license. If the A&D book is electronic, it must meet the extra requirements under ATF Ruling 2016-1 (discussed below).
ATF Ruling 2016-1
ATF Ruling 2016-1 makes certain requirements for keeping an A&D record electronically. An FFL may only use an electronic system if it meets ALL of the requirements.
We’ll introduce each requirement below along with how FFLSafe meets or exceeds the requirements.
1. Required A&D Columns/Information
All information/columns that are required in a normal (paper) A&D book must also be kept in an electronic system,
FFLSafe keeps every required column of information in the A&D book and does so cleanly in a simple display that can be downloaded, sorted, and searched.
2. Changes Must be Tracked
The ATF requires that all edits or changes to the bound book must be tracked so that they may be audited later in an inspection.
FFLSafe automatically created an audit log of every change or edit to the bound book in the “notes” column which shows the change, who made it, and when.
3. The System Must Not Rely Upon Outside Sources of Information
The ATF requires that outside sources, such as invoices or other paper/manual systems, may not be used to supply the data in the system.
FFLSafe only relies upon user-entered information upon acquisition and disposition.
4. Specific Search Capability
The ATF requires that the system must allow queries by firearm serial number, acquisition date, name of the manufacturer or importer, name of the purchaser, address of purchaser or other transferee, and ATF Form 4473 transferor’s transaction serial number (if any).
FFLSafe has a universal search bar at the top of each page that allows for searching for each required piece of information and the Bound Book in the system specifically allows for filtering, sorting, and searching for each of these pieces of information.
5. Downloads of Records
The ATF requires that the FFL download and store the A&D records to a physical storage device, or print them, semi-annually.
FFLSafe allows an easy export of the Bound Book straight to the user’s machine or it can be emailed to any email address.
6. Accessible US-Based Cloud Records
If the records are internet/cloud-based, then they must be accessible by a computer on the licensed premises and the servers must be located in the United States.
FFLSafe can be accessed by any device on-site (not just the main computer) and all of its’ servers are located in the United States.
7. Partitioned Database
The ATF requires that records are kept on a separate/[partitioned database so that it records can not be co-mingled with another licensee’s records.
FFLSafe keeps each FFL’s records separate so that they can not be mixed.
8. Daily Backups
If the FFL Software is cloud-based, then the ATF requires that there are daily on-site backups of the bound book.
Other software solutions use a 3rd party software like Box or Dropbox that you must setup and sync your software to and then also set them up to automatically save the files to your local computer.
FFLSafe skips this extra complication by providing a free backup tool that automatically downloads the backups straight to your computer. This avoids using 3rd party software (who knows what they’re doing with your information?), the associated cost and complication, and it checks that it’s working every time you open FFLSafe so, if you don’t see an error message, you know it’s working properly.
Electronic Form 4473 (e4473)
The ATF requires that purchases (transfers) of firearms from an FFL to a customer (non-FFL) be conducted only after successfully completing an ATF Form 4473.
The 4473 has information about the firearm(s) to be transferred, the customer’s biographical information and residential address, and the details and results of the background check requirements.
It is vitally important that FFLs properly complete and store these forms – 7 out of the top 10 violations every year form the ATF during inspections have to do with this form and, often, simple typos are the problem.
If you’re looking for help knowing everything there is to know about the 4473 in order to do things correctly and stay out of trouble, we strongly recommend checking out our ATF Compliance Courses.
As long as certain requirements are met (below), the 4473 may be completed electronically.
ATF Ruling 2016-2
ATF Ruling 2016-2 explains the necessary requirements for completing 4473s electronically. An FFL may only use an electronic system if it meets ALL of the requirements.
We’ll introduce each requirement below along with how FFLSafe meets or exceeds the requirements.
1. Current 4473 must be Used
The ATF requires that only the current version of the Form 4473 be used for transfers.
FFLSafe automatically updates and uses the most current version so that you never need to worry about this.
2. 4473 Definitions and Instructions
The definitions and instructions from the paper 4473 must appear exactly the same on the e4473
FFLSafe has every definition and instruction from the actual 4473 available next to every section.
3. New Form each Transaction
A new 4473 must be started for each new transaction/transfer.
FFLSafe starts an e4473 after the disposition information is ready for each transfer.
4. Customer Must be Able to Amend Answers Until Confirmed
The customer must be able to amend or change answers until they have confirmed them.
FFLSafe allows the customer to edit as they go until they are done and ready to finalize their form.
5. Customer Must Sign 4473
The customer must sign and date their form certifying their answers and information. The signatures can be either in ink or electronically on a screen or signature pad.
FFLSafe allows the customer to sign the form with their finger on their own phone’s screen or on your tablet or computer.
6. Pending Form Must be Downloaded
If there is a pending transaction, the form must be downloaded locally to a physical storage device or printed. The pending form must NOT be stored in the software system on the internet (in the cloud).
FFLSafe has the form downloaded to your computer and prompts you to print it whenever a form is pending. Unfortunately, other software options store this for you in their system – this seems convenient until you get into trouble for using software that appears to be complaint (but, in reality, is not). The exception is if you notify the ATF of the electronic host facility you are using.
