FFL Compliance Auditing & Self-Inspection 3 — Questions and Answers
Question 1: When conducting a self-inspection of Forms 4473, which section should be checked to ensure the transferee certified that they are not a prohibited person?
- Section A (Transferee Information)
- Section B (Transferee Certification) (Correct answer)
- Section C (Firearms Transaction Record)
- Section D (Transferor/Seller Certification)
Correct answer: Section B (Transferee Certification)
Section B of the Form 4473 contains the transferee's certification that all answers are true and that they are not a prohibited person under federal law.
Question 2: A self-inspection reveals that an FFL employee conducted a transfer and recorded a 'Y' (yes) response to the prohibiting question about felony conviction. What should the FFL do?
- Report the transfer to ATF as a potential violation and preserve all records (Correct answer)
- Void the Form 4473 and allow the customer to return for a corrected form
- Immediately demand the firearm's return from the transferee
- No action is needed if the NICS check came back proceed
Correct answer: Report the transfer to ATF as a potential violation and preserve all records
A 'yes' answer to a prohibiting question on Form 4473 means the transfer was to a prohibited person and must be reported to ATF immediately while preserving all records.
Question 3: What information must be recorded in the bound book when a firearm is disposed of as a sale to a non-licensee?
- Only the buyer's name and the date of sale
- The buyer's name, city and state, date of transfer, and Form 4473 transaction number (Correct answer)
- The buyer's name, address, date of birth, and SSN
- The NICS transaction number and the date of the background check only
Correct answer: The buyer's name, city and state, date of transfer, and Form 4473 transaction number
The A&D record disposition entry must include the transferee's name, city and state, date of transfer, and the Form 4473 transaction number.
Question 4: During self-inspection, an FFL finds a Form 4473 where Box 18 (type of firearm) lists 'pistol' but the bound book records the item as a 'revolver.' Which document controls for regulatory purposes?
- The bound book always controls over the Form 4473
- The Form 4473 controls because it was signed by the buyer
- Both must be corrected to match the actual firearm's ATF classification (Correct answer)
- The manufacturer's invoice controls over both documents
Correct answer: Both must be corrected to match the actual firearm's ATF classification
Both the bound book and Form 4473 must accurately reflect the firearm's actual ATF classification; discrepancies in both must be corrected.
Question 5: An FFL's self-inspection shows a NICS denial was received but the firearm was still transferred. What is the FFL's reporting obligation?
- No federal report is required; only state reporting applies
- Report the unlawful transfer to the ATF and local law enforcement immediately (Correct answer)
- File an amended Form 4473 noting the denial and transfer
- Wait 30 days to see if the denial is overturned before reporting
Correct answer: Report the unlawful transfer to the ATF and local law enforcement immediately
Transferring a firearm after a NICS denial is a federal crime; the FFL must immediately notify ATF and cooperate with the investigation.
Question 6: How frequently does ATF recommend that FFLs conduct internal self-inspections to maintain compliance readiness?
- Only when an ATF inspection is scheduled
- At least annually, or whenever significant inventory changes occur (Correct answer)
- Every five years aligned with license renewal
- Monthly, as required by federal regulation
Correct answer: At least annually, or whenever significant inventory changes occur
ATF recommends FFLs perform self-inspections at least annually and after major business changes to proactively identify and correct compliance gaps.
Question 7: Which of the following is an acceptable method for an FFL to store out-of-business records after surrendering a license?
- Destroy all records after 30 days to prevent misuse
- Retain records personally for the required period and notify ATF of storage location (Correct answer)
- Transfer all records to any licensed dealer willing to store them
- Submit all records directly to local law enforcement
Correct answer: Retain records personally for the required period and notify ATF of storage location
An out-of-business FFL must retain records for the required period, and upon surrender must notify ATF where those records will be kept.
When conducting a self-inspection of Forms 4473, which section should be checked to ensure the transferee certified that they are not a prohibited person?