Timely Recording of Firearms Acquisitions
Timely recording of firearms acquisitions within the legally mandated time frames is required of Federal Firearms Licensees (FFLs). No one wants an inspection to find a violation due to inadequate understanding of a requirement.
Each time you, as an FFL, purchase or make an acquisition of a firearm, you are required to record the activity in your acquisition and disposition (“A&D” or “bound book”) Certain information must be recorded no later than the close of business of the next business day following the acquisition. The acquisition record must show: date of receipt, name and address or name and FFL number from whom the firearm was received, manufacturer and importer (if any), model, serial number, type (of firearm), and caliber or gauge. This record can be in bound paper form or maintained electronically, per ATF Ruling 2013-5. The pertinent ATF regulation is 27 CFR 478.125 (e).
There is an exception to this requirement. ATF regulation 27 CFR 478.125(g) allows for the delay in entry of a firearm acquisition for up to seven days if the FFL has a commercial record, such as an invoice, that contains all of the information required to be recorded in the “bound book”. Further, these commercial records must be maintained separately from other commercial records maintained by the FFL and must be readily available for inspection by ATF. To reiterate: Invoices for unrecorded firearms must be filed in a systematic way so that they could be readily inspected by ATF. Even with compliant invoices properly organized, the entry in your bound book still must be made within seven days.
You can reduce the chance that you mistakenly fail to make a timely entry in your bound book, that might result in a finding of a violation during an inspection, by making it a business practice at your store to enter all acquisitions by the close of business of the next business day. If you do decide to maintain a separate file of commercial records of unrecorded firearms, make sure your system is in compliance and that you are consistent.