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Posted: 4/14/2023 10:16:29 AM EDT
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Do you all keep your NFA items in a separate bound book? Or do you lump them in with your other stuff? Thanks |
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Originally Posted By HansohnBrothers: ATF says one book only. Originally Posted By HansohnBrothers: ATF says one book only. I thought so too.........and then I found this: May a licensee maintain multiple A&D records depending on the activity conducted (e.g. A&D records for retail, gunsmithing, manufacturing, NFA, etc.)? That directly contradicts what ATF posts here:Summary of Final Rule 2021R-05F Importer and Manufacturer Marking Requirements and Records .........The records of manufacture/acquisition and disposition by manufacturers and importers must be consolidated into one book similar to dealers. The rule codifies, in part, ATF Ruling 2016-3, Consolidation of Required Records for Manufacturers and ATF Ruling 2011-1, Importers Consolidated Records, that allow licensed manufacturers and importers to consolidate their records of acquisition and disposition without obtaining a variance. I guess I'll call my IOI on Monday.  |
Plano, Texas...........the Gun Nut Capitol of Gun Culture, USA
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Originally Posted By HansohnBrothers: One book is plenty, I never understood having multiple books. Or, use FastBound and not worry about it.  Originally Posted By HansohnBrothers: One book is plenty, I never understood having multiple books. Or, use FastBound and not worry about it. I use multiple books. Fastbound looks like it would cost me $24/month, not sure it is worth it..... From Dogtown's first link: May a licensee maintain multiple A&D records depending on the activity conducted (e.g. A&D records for retail, gunsmithing, manufacturing, NFA, etc.)? Yes. Nothing in Final Rule 2021R-05F, requires licensees to use only one acquisition and disposition (A&D) record. If a licensee wishes to use more than one A&D record (e.g. manufacturing A&D record, NFA A&D record, sales A&D record, gunsmithing A&D record, etc.) they may do so, provided such information shall be recorded in formats provided in the final rule. Last Reviewed July 22, 2022 1 book is NFA items, as they tend to have LONG acquisition to disposition times..... 1 book is for "Firearms acquired from FFLs" 1 book is for "private party transfers." WA state made everything go through an FFL years ago. There are "Use Tax" implications for me on "FFL acquired firearms" that don't exist on "Private Party Transfers", so I split the books for state tax audit purposes. |
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Originally Posted By HansohnBrothers: One book is plenty, I never understood having multiple books. Or, use FastBound and not worry about it. At my second compliance inspection, the IOI asked me to start using a separate book for NFA. So I did. |
Plano, Texas...........the Gun Nut Capitol of Gun Culture, USA
https://www.youtube.com/watch?v=pELwCqz2JfE
https://www.youtube.com/watch?v=pELwCqz2JfE
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Originally Posted By DogtownTom: I thought so too.........and then I found this: May a licensee maintain multiple A&D records depending on the activity conducted (e.g. A&D records for retail, gunsmithing, manufacturing, NFA, etc.)? That directly contradicts what ATF posts here:Summary of Final Rule 2021R-05F I guess I'll call my IOI on Monday. That web page is out of date as it references 2021R-05F, and the new rule was part of the 08/24/22 package. |
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Originally Posted By RenegadeX: That web page is out of date as it references 2021R-05F, and the new rule was part of the 08/24/22 package. 2021R-05F was effective 8/24/22. |
Plano, Texas...........the Gun Nut Capitol of Gun Culture, USA
https://www.youtube.com/watch?v=pELwCqz2JfE
https://www.youtube.com/watch?v=pELwCqz2JfE
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OK so I did just check the CFR and it appears 478.123 Records maintained by manufacturers is current. CFR 478.123 It points out the older 3 book system is now a nogo. This was also pointed out in the PowerPoint Presentation at page 44.  FINAL RULE 2021R-05F-Definition of "Frame or Receiver" and Identification of Firearms |
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Originally Posted By HansohnBrothers: Yes, only 1 book now. Not exactly. Previously to 2021R-05F, manufacturers could have a separate A&D book for firearms manufactured, a separate book for transfers to licensees and a separate book for transfers to nonlicensees. A single firearm could have transferred between those three books. Now, ATF wants the acquisition and disposition of that firearm recorded in a single book. That's different than having a manufacturing book, an NFA book and a gunsmithing book as those books would not have entries for the same firearm. So.........one firearm......recorded in one book only. |
Plano, Texas...........the Gun Nut Capitol of Gun Culture, USA
https://www.youtube.com/watch?v=pELwCqz2JfE
https://www.youtube.com/watch?v=pELwCqz2JfE
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Originally Posted By DogtownTom: Not exactly. Previously to 2021R-05F, manufacturers could have a separate A&D book for firearms manufactured, a separate book for transfers to licensees and a separate book for transfers to nonlicensees. A single firearm could have transferred between those three books. Yup, and that system was almost impossible to reconcile. Only on my first inspection did they do it. After that they all punted and asked for a list of firearms that should be in the safe. So 3 book system is out, and you go to the single book format in 478.123. |
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Originally Posted By RenegadeX: Yup, and that system was almost impossible to reconcile.... I almost feel sorry for the IOI's that had to explain how a three book system was supposed to work. |
Plano, Texas...........the Gun Nut Capitol of Gun Culture, USA
https://www.youtube.com/watch?v=pELwCqz2JfE
https://www.youtube.com/watch?v=pELwCqz2JfE
Don't let the join date fool you... here since '97
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| Honestly, just use Fastbound . It takes all the guess work out. |
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Originally Posted By HansohnBrothers: Honestly, just use Fastbound . It takes all the guess work out. Seems like it's well worth the price for the piece of mind. Especially if you aren't a paperwork loving individual |
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Just bumping this back up. My IOI was super green so I don't necessarily trust her at this point. However, she stated 1 book for non-NFA, 1 book for NFA, and 1 book for gunsmithing. That was several months ago. I don't do much volume. I'd prefer to just use one book. What is the ATF saying in 2024? |
You think you're winning this game? You don't even know the God-damned rules. But don't worry, I'm gonna teach 'em to ya..
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Originally Posted By alpha0815: Just bumping this back up. My IOI was super green so I don't necessarily trust her at this point. However, she stated 1 book for non-NFA, 1 book for NFA, and 1 book for gunsmithing. That was several months ago. I don't do much volume. I'd prefer to just use one book. What is the ATF saying in 2024? Nothing has changed. |
Plano, Texas...........the Gun Nut Capitol of Gun Culture, USA
https://www.youtube.com/watch?v=pELwCqz2JfE
https://www.youtube.com/watch?v=pELwCqz2JfE
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