Compliance Auditing & Self-Inspection Flashcards

A licensed collector (Type 03 C&R) is subject to which specific self-inspection recordkeeping requirement that differs from a Type 01 dealer?

Answer: C&R licensees must maintain a bound book of C&R firearm acquisitions and dispositions but are exempt from NICS for C&R-eligible firearms

Type 03 C&R licensees must maintain an A&D record for curio and relic firearms but are generally exempt from NICS checks when acquiring C&R-eligible firearms from dealers.

During self-inspection, an FFL discovers that multiple sales reports (ATF Form 3310.4) for handgun sales to the same buyer were never submitted. What is the reporting threshold that triggers this requirement?

Answer: Three or more handguns purchased by the same person in any 5-business-day period

An FFL must file ATF Form 3310.4 when the same person purchases two or more handguns during any five consecutive business days.

What is the purpose of reconciling the physical inventory count against the bound book during a self-inspection?

Answer: To identify unrecorded acquisitions, missing disposition entries, or actual theft/loss

Physical-to-book reconciliation identifies discrepancies that may indicate unrecorded transactions, missing firearms, or theft requiring ATF notification.

An FFL operating a gun show booth discovers mid-show that its portable bound book was left at the licensed premises. Under ATF regulations, what must the FFL do?

Answer: Cease making transfers until the bound book or an authorized copy is available at the booth

An FFL must have its acquisition and disposition records available at the location where transfers are occurring; without them, transfers must cease.

Which of the following correctly describes the 'open and voluntary' disclosure concept in ATF compliance inspections?

Answer: An FFL that discloses violations to ATF before an inspection begins may receive reduced penalties

FFLs that proactively disclose violations before or at the start of an ATF inspection may receive more favorable treatment, though willful violations are not mitigated.

During self-inspection, what should an FFL verify regarding the storage of completed Forms 4473 to ensure regulatory compliance?

Answer: Forms may be stored in any order as long as they can be produced within 24 hours of an ATF request

ATF does not mandate a specific filing order for Forms 4473 but requires that they be retrievable and produced within 24 hours of an ATF request.

What is the significance of the 'three strikes' provision under ATF's willful violation enforcement framework during compliance inspections?

Answer: Repeated identical violations across inspections can demonstrate willfulness supporting revocation

Recurring violations of the same type across multiple ATF inspections can establish willfulness — a key element for license revocation under the GCA.