FFL Compliance Auditing & Self-Inspection 4 — Questions and Answers
Question 1: What ATF tool is available to help FFLs voluntarily evaluate their own compliance before an official inspection?
- ATF Form 7 (Application for License)
- ATF's FFL Self-Inspection Checklist published on atf.gov (Correct answer)
- ATF Form 3310.4 (Multiple Handgun Purchase Report)
- ATF's Industry Operations Inspector manual
Correct answer: ATF's FFL Self-Inspection Checklist published on atf.gov
ATF publishes a self-inspection checklist on atf.gov that FFLs can use to proactively assess their own compliance with recordkeeping and inventory requirements.
Question 2: A licensed dealer discovers during self-inspection that 10 long guns were never entered into the bound book because they were received as consignment. How should these be recorded?
- They need not be recorded because consignment guns are not owned by the dealer
- They must be recorded as acquisitions at the time of receipt into the dealer's inventory regardless of ownership (Correct answer)
- Only guns that sell from consignment need to be recorded
- They should be recorded only in a separate consignment log, not the A&D record
Correct answer: They must be recorded as acquisitions at the time of receipt into the dealer's inventory regardless of ownership
All firearms received into an FFL's inventory — including consignment — must be recorded as acquisitions in the bound book upon receipt.
Question 3: During a physical inventory audit, an FFL finds a firearm whose serial number has been partially obliterated. What is the required action?
- Attempt to restore the serial number using chemical etching
- Do not transfer the firearm and contact ATF for guidance (Correct answer)
- Record the partial number in the bound book and proceed with any sale
- Return the firearm to the manufacturer for re-serialization
Correct answer: Do not transfer the firearm and contact ATF for guidance
Possessing or transferring a firearm with an obliterated serial number is a federal crime; the FFL must not transfer it and should contact ATF for instructions.
Question 4: When verifying Form 4473 compliance during self-inspection, which field error would make a transfer legally invalid rather than just a recordkeeping deficiency?
- The buyer's middle name is abbreviated instead of written in full
- The date of birth is written in MM/DD/YY format instead of MM/DD/YYYY
- The buyer answered 'no' to being a prohibited person but is in fact prohibited (Correct answer)
- The FFL's license number has a transposed digit in Box 27
Correct answer: The buyer answered 'no' to being a prohibited person but is in fact prohibited
A false answer to a prohibiting question means the transfer was to a prohibited person, making it an illegal transfer — not merely a paperwork error.
Question 5: An FFL's bound book is maintained electronically. Which requirement must the electronic system meet to comply with ATF regulations?
- It must be accessible only to ATF and not to employees
- It must be capable of producing a hard-copy printout of all required A&D information (Correct answer)
- It must use ATF-approved software certified annually
- It must be backed up to ATF's servers in real time
Correct answer: It must be capable of producing a hard-copy printout of all required A&D information
Electronic bound books are permitted but must be capable of producing a legible hard-copy printout of all required acquisition and disposition information upon ATF request.
Question 6: What does an ATF compliance inspection 'report of violations' (ROV) document?
- Criminal charges filed against the FFL by the U.S. Attorney
- Specific regulatory violations found during the inspection with corrective action requirements (Correct answer)
- The IOI's personal opinion on the quality of the FFL's business practices
- A list of firearms the FFL is prohibited from selling
Correct answer: Specific regulatory violations found during the inspection with corrective action requirements
An ATF Report of Violations formally documents specific regulatory violations found during a compliance inspection and notifies the FFL of required corrective actions.
Question 7: Which of the following actions by an FFL would constitute willful violation of the GCA, potentially supporting license revocation?
- Filing a late multiple sales report by two days due to a system outage
- Repeatedly transferring firearms without completing Form 4473 after being warned by ATF (Correct answer)
- Making a single bound book entry error that was later corrected
- Conducting a NICS check one hour before the buyer arrived at the store
Correct answer: Repeatedly transferring firearms without completing Form 4473 after being warned by ATF
Repeatedly bypassing Form 4473 requirements after ATF warnings demonstrates willful disregard of the GCA, which is grounds for license revocation under 18 U.S.C. § 923(e).
FFL Compliance Auditing & Self-Inspection 4
What ATF tool is available to help FFLs voluntarily evaluate their own compliance before an official inspection?