Can a FFL have multiple locations?...
Got some kind of technical questions about FFLs & locations...
Can a FFL make deliveries to or pick up firearms from a customer provided everything is logged and the NICS is executed etc? I don't think so, but I wanted to check to make sure. Like say if a gun smith went to a customer to pick up his gun, or to drop it off afterwards?
Is a FFL proper to an address. Like if Joe's Gun shop did well & he opened a second location across town is that another FFL? What about if Joe want to conduct business at a shop downtown on M-W and at the beaches on Th-St? Is that two different FFLs?
Can a FFL conduct business anywhere other than the main address listed on the FFL? And by business I specifically mean receiving or transferring an actual firearm. Apparently a FFL CAN do this sometimes since they buy/sell guns at gun shows. Is this a special dispensation?
Here is what I am driving at:
I am wanting to get into the firearms service business, working out of my home but so that the customer does not need to come from all the way from town to my house. If I can't do pickup/deliveries from the customer, I was wondering if I could conduct transfers in town in some sort of shared office space, or "virtual office." These are places that cater to transient professionals or to local people w/ home based business that occasionally need to meet with clients. There is a receptionist type lady on staff for calls and deliveries and offices/board rooms that you can rent or lease.
The point is that I am trying to avoid the overhead of a regular retail space with a low to no inventory service oriented business model.
I would prefer to register the FFL at home and then occasionally conduct business(transfers) from one or more of these type of spaces in town. If local .gov or ATF says that is a no go, then can I register the FFL to one of these type of places?
If you look at your FFL license, it will state the premise address. That is the only place you are allow to conduct business. You will need a separate license for each location.
Originally Posted By sumkrnboy:
If you look at your FFL license, it will state the premise address. That is the only place you are allow to conduct business. You will need a separate license for each location.
This is NOT a true statement.
It's pretty close to correct, unless you're referring to the gun show exception.
§ 478.50 Locations covered by license.
The license covers the class of business
or the activity specified in the license
at the address specified therein. A separate
license must be obtained for each
location at which a firearms or ammunition
business or activity requiring a license
under this part is conducted except:
(a) No license is required to cover a
separate warehouse used by the licensee
solely for storage of firearms or ammunition
if the records required by this part are
maintained at the licensed premises
served by such warehouse;
(b) A licensed collector may acquire
curios and relics at any location, and dispose
of curios or relics to any licensee or
to other persons who are residents of the
State where the collector's license is held
and the disposition is made;
(c) A licensee may conduct business at
a gun show pursuant to the provisions of
§ 478.100; or
(d) A licensed importer, manufacturer,
or dealer may engage in the business of
dealing in curio or relic firearms with another
licensee at any location pursuant to
the provisions of § 478.100.
Exactly...so the premise is NOT the only place business can be conducted...478.100 covers other locations besides the premise and gun shows. Example: Local gun club shooting event.
Originally Posted By rightwingnut:
Can a FFL make deliveries to or pick up firearms from a customer provided everything is logged and the NICS is executed etc?
No.
Thanks guys. So save gun show or shooting event if I want to do actual transfers to or from an individual or representive of a trust or corporation at some sort of office space I need to have the ffl registered there.
And the inventory may only be stored at the ffl address or at a warehouse but the records must be kept at the ffl address. So to run a gun business out of a shared office type place where I would actually do transfers I would have to permanantly store at least a small gun safe and the ffl files there.
So once I take possession of a gun at said office space can I take it elsewhere to service it or ship it or test it??
Originally Posted By rightwingnut:
Thanks guys. So save gun show or shooting event if I want to do actual transfers to or from an individual or representive of a trust or corporation at some sort of office space I need to have the ffl registered there.
Your transfers must take place at the licensed location (exception being in-state gunshows). So, yes.
And the inventory may only be stored at the ffl address or at a warehouse but the records must be kept at the ffl address. So to run a gun business out of a shared office type place where I would actually do transfers I would have to permanantly store at least a small gun safe and the ffl files there.
See above, yes, your transfers must be done there. You can store at a seperate location but if you're inspected by ATF then they will want to go to the seperate location to conduct an inventory. All records must be kept at your licensed address but there is no requirement to have a safe.
So once I take possession of a gun at said office space can I take it elsewhere to service it or ship it or test it??
You can take it out to test fire etc. However, if you're running a gunsmithing operation at a different location you would need to be licensed there too.
Originally Posted By rcoers:
Originally Posted By rightwingnut:
...
So once I take possession of a gun at said office space can I take it elsewhere to service it or ship it or test it??
You can take it out to test fire etc. However, if you're running a gunsmithing operation at a different location you would need to be licensed there too.
Damn it! Well, what do you mean by "running an operation." What if I always worked on the guns at home but NEVER transferred them to or from a customer anywhere except at the office in town where the FFL is registered? Is this uncharted territory?
Could I just get two FFLs, one for in town and one for out in the country at home? Could I take customer's guns to and fro between them? Would I have to be logging the gun in the books from one the the other, back and forth w/ every trip?
Thx Guys
Okay, so there is no requirement to have a safe at the FFL registered address. Do we think I could list my house as a "warehouse" for any inventory I have? This would only consist of maybe a few customers guns for work/test firing.
I know all the stuff about having to keep personal and business stuff separate or clearly labeled.
Originally Posted By rightwingnut:
Originally Posted By rcoers:
Originally Posted By rightwingnut:
...
So once I take possession of a gun at said office space can I take it elsewhere to service it or ship it or test it??
You can take it out to test fire etc. However, if you're running a gunsmithing operation at a different location you would need to be licensed there too.
Damn it! Well, what do you mean by "running an operation." What if I always worked on the guns at home but NEVER transferred them to or from a customer anywhere except at the office in town where the FFL is registered? Is this uncharted territory?
By running an operation I mean that you'd be taking guns to a 2nd location and be working on them. If you're doing all your gunsmithing there it needs to be a licensed location. I think you are way over complicating this.
Could I just get two FFLs, one for in town and one for out in the country at home? Could I take customer's guns to and fro between them? Would I have to be logging the gun in the books from one the the other, back and forth w/ every trip?
Yes, you could get 2 FFLs but this seems dumb to me. Find a location that you can get properly zoned and do everything there. And yes, if you have 2 licenses the firearms will need to be logged in and out if they're going from one licensed location to another. Again, I think your plans of doing everything from 2 locations is setting yourself up for a lot of unnecessary work and headache.
Thx Guys
Before you proceed any further with this, I'd take 5 minutes and call your local zoning. For all you know they may allow a home occupation for gunsmithing.
Originally Posted By rightwingnut:
Damn it! Well, what do you mean by "running an operation."
Engaging in the business of dealing in firearms or gunsmithing.
What if I always worked on the guns at home but NEVER transferred them to or from a customer anywhere except at the office in town where the FFL is registered?
You would be engaging in the business at an unlicensed premises.
Is this uncharted territory?
No.
Could I just get two FFLs, one for in town and one for out in the country at home?
Yes.
Could I take customer's guns to and fro between them?
Yes.
Would I have to be logging the gun in the books from one the the other, back and forth w/ every trip?
Exactly.
Sigh. Okay. Thx guys. I am most impressed with the detailed succinct info in this forum. I know what I need to know now.
