ATF Q&A: A & D Records

Unfortunately, marking requirements that existed before 1968 did not apply to all firearms. Many of the firearms manufactured and imported prior to 1968 bear no serial numbers or other markings. Licensees who receive these firearms should note in each descriptive column in the acquisition record the physical markings that appear on the firearms. If no serial number was placed on the firearm, it should be specifically noted that “Firearm has no serial number” or recorded “NSN.” Remember, however, it is illegal to remove or alter a firearm’s serial number, and a licensee should report such a firearm to the nearest ATF office. Refer to the ATF P 3317.2, Safety and Security Information for Federal Firearms Licensees.

You may maintain records of acquisition and disposition in a binder or spiral-bound format, as long as the holes that are punched do not remove or obstruct any required information. The format must follow that prescribed in the regulations, and the pages must be numbered consecutively. [27 CFR 478.121 and 478.125] If you use a three-ring binder or a spiral notebook for the A&D records, you must be careful to ensure that no pages get lost.

The column heading “Manufacturer and/or Importer” has long been a bit of a misnomer.  Since the publication of the 2014 edition of the ATF “Federal Firearms Regulations Reference Guide” (the white book), ATF has officially modified the table that shows the required format of A&D records to change that heading to, “Manufacturer and Importer (if any)”.  Both the name of the foreign manufacturer and the name of the U.S. importer have been required in the A&D records since the regulations were written, but the example table showed that somewhat misleading column label in the regulations.  If a firearm is manufactured outside the United States and imported into the United States, both the foreign manufacturer’s name and the U.S. importer’s name must be shown in the A&D records.  That information is required to be engraved on the firearm, and FFLs should get that information from physically examining every firearm.  (NOTE:  While there is a minor exception to this requirement in the instructions for block 24 of ATF Form 4473, we recommend that the A&D description and the Form 4473 Section D description be identical for every firearm.  There is no valid reason for them to be different.)”

Imported firearms are required to be engraved with both the name of the foreign manufacturer and the name of the domestic importer, even if they are the same company. Therefore, the names as marked on the firearm for the manufacturer and for the importer are the names that should be entered into the A&D Book.

 

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The information required to be entered refers to the “types” of firearms as defined by 27 CFR 478.11 and 479.11.  Types such as pistol, revolver, rifle, shotgun, frame, receiver, pistol grip firearm, silencer, any other weapon (AOW) etc., are all acceptable.  Entries such as semi-automatic, bolt, lever, etc., are not types of firearms and are not acceptable in the type of firearm field.

For more information on this question, please see this article: A&D Entries for Type of Firearm

 

Yes, you must keep your inventory for each FFL separate and use separate record-keeping for each.

 

24-Hour Compliance Hotline

NSSF members can greatly benefit from the NSSF’s Retail Member Hotline. The toll-free hotline will bring calls in to the NSSF headquarters on a 24/7 basis. If questions regarding compliance, transactions, legislation or any other topic cannot be answered at the time of the call, an all-out attempt will be made to provide the answer within 24 hours.

NSSF members have exclusive 24/7 access to the NSSF’s Retail Member Hotline. Non-member retailers can view some of the questions that have been asked and answered through this service here.

Compliance Resources for Members

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Since 1968, the data FFLs have needed to enter in their firearms A&D record for imported firearms has included both the foreign manufacturer and the US importer.  As stated in ATF regulation 27 CFR 478.125 (e), “The record shall show the date of receipt, the name and address or the name and license number of the person from whom received, the name of the manufacturer and importer (if any), the model, serial number, type, and the caliber or gauge of the firearm….”

Since August 24, 2022, the column heading where this information is entered is “Manufacturer, importer and/or ‘Privately Made Firearm’ (PMF) (If privately made in the U.S.)”.

A very common way that FFLs enter this information is with a ‘/’ between manufacturer and importer ‘Umarex/FN America’. 

For all imported firearms, this information is on the firearm.  Be sure to examine them carefully, particularly shotguns, to locate it.

FFLs need to be mindful that the same information should be recorded on question 1 of Form 4473.

 

 

24-Hour Compliance Hotline

NSSF members can greatly benefit from the NSSF’s Retail Member Hotline. The toll-free hotline will bring calls in to the NSSF headquarters on a 24/7 basis. If questions regarding compliance, transactions, legislation or any other topic cannot be answered at the time of the call, an all-out attempt will be made to provide the answer within 24 hours.

NSSF members have exclusive 24/7 access to the NSSF’s Retail Member Hotline. Non-member retailers can view some of the questions that have been asked and answered through this service here.

Compliance Resources for Members

NSSF offers an array of resources and information to help members operate their businesses in compliance with laws and regulations. NSSF’s regulatory compliance resources include articles, newsletters, videos, online training courses, legal and regulatory compliance consultants and more. Log in to access.