Firearms Inspections ONLY

Industry Operations Investigator's Role

• Conduct qualification inspections to verify the accuracy of the application and determine the applicant's ability to comply with ATF requirements
• Ensure firearms industry members are not prohibited from engaging in licensed business operations
• Assist the industry member in understanding Federal laws and regulations
• Conduct inspections to determine compliance with Federal firearm laws and regulations
• Pursue and recommend adverse action, such as a warning conference and warning letter
• Assist the industry member in achieving compliance with Federal laws and regulations
• Identify patterns of illegal firearms transactions
• Refer tax liability related questions or concerns to the Alcohol and Tobacco Tax and Trade Bureau (TTB)

Types of Federal Firearms Licenses (FFL)

• Dealer (01): includes Pawnbroker (02) and Gunsmith activities
• Collector of Curios and Relics (Type 03)
• Manufacturer of Ammunition for Firearms Other Than Destructive Devices or Armor Piercing Ammunition (Type 06)
• Manufacturer of Firearms Other Than Destructive Devices (Type 07)
• Importer of Firearms Other Than Destructive Devices or Ammunition for Firearms Other Than Destructive Devices, or Ammunition Other Than Armor Piercing Ammunition (Type 08)
• Dealer in Destructive Devices (Type 09)
• Manufacturer of Destructive Devices, Ammunition for Destructive Devices or Armor Piercing Ammunition (Type 10)
• Importer of Destructive Devices, Ammunition for Destructive Devices or Armor Piercing Ammunition (Type 11)

Firearms Qualification Inspections

• Conducted to determine whether the proposed business activity requires an FFL and whether the application is for the proper type of license
• Verify the applicant's ability to comply with state and local laws
• Identify ownership and control
• Inform applicants of the laws and regulations governing their activities
• Minimize or eliminate the possibility of a firearms dealer being a prohibited person
• Reduce illegal diversion and ensure the integrity of the records system

General Steps for Firearms Qualification Inspections

• Review ATF Form 7 (5310.12) and supporting documents
• Make an appointment with the applicant
• Verify the applicant's identity and record that information
• Examine available business documents
• Verify ownership and/or control and identify responsible persons
• Educate the licensee by explaining record keeping and reporting requirements

Closing Actions

• Advise the applicant of your recommendation
• Advise the applicant of renewal procedures
• Advise the applicant of how to obtain ATF forms
• Have the applicant sign an Acknowledgment of the Federal Firearms Regulations

Collector of Curios and Relics (Type 03 FFL)

• Required to keep bound book records
• Does not execute ATF Forms 4473, nor do they conduct NICS criminal background checks

Manufacturer (Ammunition), Type 06 FFL

• No formal record-keeping requirements
• Required to maintain commercial records sufficient to substantiate the tax return### Privately Made Firearms (PMFs)
• A PMF is a firearm made by a non-licensee without a serial number.
• If a licensed dealer, manufacturer, or importer receives a PMF, they must record it as an acquisition in their Acquisition and Disposition (A&D) records.
• The licensee must mark the PMF with a unique serial number starting with their FFL's abbreviated license number (first three and last five digits) followed by a hyphen and a unique identification number.

Marking and Recording PMFs

• The markings must be completed within seven days of receipt or before disposition, whichever is sooner.
• A licensee can take a PMF off-premises for marking purposes to another licensee or non-licensee, but only under direct supervision.

Examine Acquisition and Disposition (A&D) Records

• Examine A&D records for:
  • Format
  • Timely entries
  • Completeness
  • Accuracy

Physical Inventory and Safe Handling

• Industry Operations Investigators handle firearms during:
  • Inventory
  • Checking markings and serial numbers
  • Measuring for barrel or overall length for NFA compliance
  • Examination for NFA conversion
• Safety rules:
  • Treat every firearm as if it's loaded
  • Keep muzzle pointed in a safe direction
  • Keep fingers off the trigger and away from the trigger guard
  • Determine if the weapon is loaded before handling
  • Remove the source of ammunition and open the action
  • Inspect the action and chamber
• Additional safety guidelines:
  • Never pretend to have more knowledge than you do
  • Never rely on mechanical safety or someone else checking the firearm

Etiquette and Handling

• Always ask to handle firearms, as they are private property
• Remove rings and jewelry that could scratch firearms
• Ensure hands are clean before handling firearms
• Wipe metal parts after handling each firearm
• Avoid dry-firing or repeatedly working the action of any firearm, especially collectible ones
• Close the action of any firearm gently

Conducting Physical Inventory

• A complete physical inventory allows the Industry Operations Investigator to:
  • Determine the accuracy of the licensee's records
  • Examine inventory for illegal firearms (unregistered NFA weapons, obliterated serial numbers, illegal conversions, etc.)
  • Verify proper marking of firearms
  • Identify problems, such as storage of business inventory with personal (unmarked) firearms
• Industry Operations Investigators (IOIs) must conduct full inventory verification, regardless of the number of firearms in the licensee's inventory.