Questions about the 03 FFL

cessnapilot · Jul 3, 2020

I’m interested in getting an O3FFL and think I understand the application process and limits on what you can do with a 03FFL. What I don’t fully understand is the ATF inspection. I understand that the ATF inspection can occur annually and without a warrant and is primarily for inspecting your bound book. But do you have to allow access/inspection of your non C&R firearms as well or other areas of your residence? I’ve also heard that you can opt to have the inspection at a field office as well? I appreciate any first hand feed back.

KH195 · Jul 3, 2020

You are correct, ATF technically can request an inspection annually if they so choose. It would pertain to your C&R firearms and bound book only. It can be done at your home or you can request that it happen at the nearest ATF field office. You may have a tough time finding someone with first hand knowledge of the process though as it is very rare for this to happen with 03FFLs (unless you were doing something to get their attention). Not saying you won’t get randomly picked, but 03FFLs typically aren’t a priority for inspections.

bpm32 · Jul 3, 2020

Nope, just firearms in the bound book is my understanding.

I think I’ve seen one or two posts in various forums over the years of people being called for an inspection, but I think it’s very rare.

JohnC · Jul 3, 2020

KH195 said:
You are correct, ATF technically can request an inspection annually if they so choose. It would pertain to your C&R firearms and bound book only. It can be done at your home or you can request that it happen at the nearest ATF field office. You may have a tough time finding someone with first hand knowledge of the process though as it is very rare for this to happen with 03FFLs (unless you were doing something to get their attention). Not saying you won’t get randomly picked, but 03FFLs typically aren’t a priority for inspections.

Seconded. I've had mine for almost 2 years and haven't heard a peep regarding an inspection. KH195 is correct regarding the location and scope of the inspection, to my knowledge. Keep your bound book updated (go and buy a notebook, don't use the paper they give you) and you should be fine. I've never heard of the ATF doing midnight no-knock raids for an 03FFL unless you're up to no good

rseymorejr · Jul 3, 2020

I've had an 03 for almost 9 years. They have never contacted me about lookin at my book. If thye ever do it'll be at a McDonalds, Starbucks or park bench somewhere.

Bob A · Jul 3, 2020

Ten years, zero contacts.

I recall one guy many years ago got an audit; the examiner didn't like the way he did his bound book; made him do it over. Reminiscent of the 4th grade with Sister Mary Cordite.

cessnapilot · Jul 3, 2020

Thanks for the quick replies! I suspected it was rare but it sounds even more rare than I had thought.

John from MD · Jul 3, 2020

I had one for about 30 years. We had one MDS member who was called about an inspection in his home. He allowed the auditor to come and it was no big deal. The problem was that the agent wasn't familiar with 003 rules. They can request an inspection of your bound book and collection. However, the rule allows you to request an inspection at the BATF facility. I know one person who got called and requested the inspection at the Baltimore Field Office. The auditor told him "just bring your book in then."

That's the only two I know of personally that ever got asked about an inspection.

cessnapilot · Jul 3, 2020

John from MD said:
I had one for about 30 years. We had one MDS member who was called about an inspection in his home. He allowed the auditor to come and it was no big deal. The problem was that the agent wasn't familiar with 003 rules. They can request an inspection of your bound book and collection. However, the rule allows you to request an inspection at the BATF facility. I know one person who got called and requested the inspection at the Baltimore Field Office. The auditor told him "just bring your book in then."

That's the only two I know of personally that ever got asked about an inspection.

Thanks! This is pretty much the type of answer I was looking for!

rseymorejr · Jul 3, 2020

I've read where some people don't renew, they let the license lapse for a bit and then reapply. That way you can dump the old bound book and start fresh. I never really saw the need to do that though.

Darkemp · Jul 3, 2020

rseymorejr said:
I've read where some people don't renew, they let the license lapse for a bit and then reapply. That way you can dump the old bound book and start fresh. I never really saw the need to do that though.

Renewed mine once and then allowed it to lapse due to possibly moving. No contacts and now my book is irrelevant.

John from MD · Jul 3, 2020

rseymorejr said:
I've read where some people don't renew, they let the license lapse for a bit and then reapply. That way you can dump the old bound book and start fresh. I never really saw the need to do that though.

That's true. The law no longer applies to you once you let your license expire. There is no provision for keeping your records or sending them to West Virginia.

tallen702 · Jul 3, 2020

rseymorejr said:
I've read where some people don't renew, they let the license lapse for a bit and then reapply. That way you can dump the old bound book and start fresh. I never really saw the need to do that though.

It lets you off-book prior acquisitions. Most guys who expire and then re-apply do so for the reason that their book got out of hand over the years and there was no way they could rectify the situation without un-licensing and starting over with a clean slate. I knew a guy who kept everything on a post-it pad with the intention of entering the info.... someday.... until he lost the pad. He, under the advice of a 2A lawyer, allowed his license to expire and now keeps meticulous records of any transactions.

Some folks are just paranoid and want to get everything off-book every 3 years so that if some sort of ban comes down, there's no paper trail.

That said, I've never lapsed, always renewed.

For OP, I've never had a visit or call other than the automated FFL alerts during the recent riots. The only guy I know that ever had a visit from the BATFE was flagged because he was buying multiples from wholesalers on a regular basis. The BATFE was concerned he was in the business of dealing without a proper FFL for that, but he simply had the cash to throw around and would buy 3 or 4 of a gun depending on price and keep the best examples for himself, hang on to the others for a while, and then sell them bit by bit as time allowed. They were okay-ish with that, but still giving him a bit of a side-eye. His book was in order than the spot-checks with other 03FFLs matched up on the info for the transfers he made.

John from MD · Jul 3, 2020

tallen702 said:
It lets you off-book prior acquisitions. Most guys who expire and then re-apply do so for the reason that their book got out of hand over the years and there was no way they could rectify the situation without un-licensing and starting over with a clean slate. I knew a guy who kept everything on a post-it pad with the intention of entering the info.... someday.... until he lost the pad. He, under the advice of a 2A lawyer, allowed his license to expire and now keeps meticulous records of any transactions. .

That's about the facts of it. Many people who I knew when I had my gunsmith business, had C&R FFL's and bought at gunshows and before those, at club flea markets. Many times they failed to get all the info for their bound book and sweated it out until it expired. Then they would reapply and start a new book.

They weren't trying to beat the system, they were just bad book keepers. Many 01 FFL's got into hot water for paperwork errors. I used to offer training and a manual for FFL's that got bad audits. Back then, the BATF was willing to work with them and accepted my program as a fix and they only got a warning. Most BATF auditors back then were former employees in a firearms business of some sort and were decent, knowledgeable people. In later years, they started hiring people with no experience and all they knew was the regulations. :sad20:

lazarus · Jul 4, 2020

John from MD said:
That's about the facts of it. Many people who I knew when I had my gunsmith business, had C&R FFL's and bought at gunshows and before those, at club flea markets. Many times they failed to get all the info for their bound book and sweated it out until it expired. Then they would reapply and start a new book.

They weren't trying to beat the system, they were just bad book keepers. Many 01 FFL's got into hot water for paperwork errors. I used to offer training and a manual for FFL's that got bad audits. Back then, the BATF was willing to work with them and accepted my program as a fix and they only got a warning. Most BATF auditors back then were former employees in a firearms business of some sort and were decent, knowledgeable people. In later years, they started hiring people with no experience and all they knew was the regulations.

Mines pretty good. Though I did almost forget to get an FFL-01’s license when I traded in a C&R on newer used gun. Other than a quick spot check it wouldn’t have been that big a deal as I could have easily gotten a copy when I went to out the disposition in to my bound book.

Brownell’s has paper bound books for like $5. Setup the way they are supposed to be. I doubt I’ll fill mine in my lifetime.

I can try though.

Docster · Jul 5, 2020

cessnapilot said:
I’m interested in getting an O3FFL and think I understand the application process and limits on what you can do with a 03FFL. What I don’t fully understand is the ATF inspection. I understand that the ATF inspection can occur annually and without a warrant and is primarily for inspecting your bound book. But do you have to allow access/inspection of your non C&R firearms as well or other areas of your residence? I’ve also heard that you can opt to have the inspection at a field office as well? I appreciate any first hand feed back.

Check out the FAQ section. Many answers to common question on everything C & R. You'll learn much that you need to be an FFL03

mac1_131 · Jul 5, 2020

Rarely happens. I’ve only heard of one, a friend of mine, and it went fine.

cessnapilot · Jul 11, 2020

Well, I mailed off my application earlier this week! But now I’m starting to think this is going to get expensive! Lol! Thanks everyone for the replies!

John from MD · Jul 11, 2020

Well, if avgas is still around $6 a gallon, you will definitely have to make some serious choices when you get that FFL. :lol:

cessnapilot · Jul 12, 2020

John from MD said:
Well, if avgas is still around $6 a gallon, you will definitely have to make some serious choices when you get that FFL.

Haha! Well, it’s typically under $5 a gallon now but fortunately someone else now paying me to burn their avgas!

Questions about the 03 FFL

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