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 questions before I turn in my FFL application
whiskeyjacked  [Team Member]
1/10/2012 9:22:12 PM
I have a few questions that hopefully you guys can answer for me before I send in my application, regarding my unique situation (that I am wondering if the ATF is going to approve).

So my situation in a nutshell: I'm a military spouse with most of the kid raising responsibility. I also have been dragging around a machine shop for the last two PCS's and would like to start putting it to use on some gunsmithing work.

Questions:
1. Can I do work at my machine shop, and ship and receive guns at my home which are 15 miles apart and in different counties under the same license? I'm just not at the shop regular enough under normal UPS/FED-EX hours to receive shipments regularly due to running the kid around during the day. Or can you use a shipment receiving service such as the UPS store and just go pick up shipments without having to catch the truck?

2. Can a 4yr old hang out at the "gunsmithing site" on a fairly regular basis without upsetting the ATF?

3. How hard would it be maintaining an FFL moving every two or three years? And what would happen if the military moved us overseas again?

their FAQ's didn't seem to answer these, so maybe you guys might be able to help me out. thanks in advance.
Bubbles  [Team Member]
1/10/2012 9:34:25 PM
Originally Posted By whiskeyjacked:
I have a few questions that hopefully you guys can answer for me before I send in my application, regarding my unique situation (that I am wondering if the ATF is going to approve).

So my situation in a nutshell: I'm a military spouse with most of the kid raising responsibility. I also have been dragging around a machine shop for the last two PCS's and would like to start putting it to use on some gunsmithing work.

Questions:
1. Can I do work at my machine shop, and ship and receive guns at my home which are 15 miles apart and in different counties under the same license? I'm just not at the shop regular enough under normal UPS/FED-EX hours to receive shipments regularly due to running the kid around during the day. Or can you use a shipment receiving service such as the UPS store and just go pick up shipments without having to catch the truck?

2. Can a 4yr old hang out at the "gunsmithing site" on a fairly regular basis without upsetting the ATF?

3. How hard would it be maintaining an FFL moving every two or three years? And what would happen if the military moved us overseas again?

their FAQ's didn't seem to answer these, so maybe you guys might be able to help me out. thanks in advance.

For #1, the shop is the premises address and the home as the mailing address, and have a good safe at the shop. Note that some FFL's will insist on sending everything to the "premises" only.

For #2, the ATF won't care. Having said that, we run a shop in the garage and I would not recommend a preschooler hanging about while you're working. Way too much potential for things going sideways. Arrange for day care.

For #3, depends on the state. Some states it'll be easy to get an FFL, while others (CA, NY) make it a major PITA. FFL's can not be licensed for a non-US location.

I would also check into what's required to move LLC's around between states, as you really don't want to operate as a sole proprietor.
DogtownTom  [Team Member]
1/10/2012 11:30:39 PM
Originally Posted By whiskeyjacked:
Or can you use a shipment receiving service such as the UPS store and just go pick up shipments without having to catch the truck?


Yes, I do this.
The UPS Store is my "mailing address" on my FFL.

They'll accept and hold packages from UPS/FedEx/USPS/etc.
whiskeyjacked  [Team Member]
1/11/2012 4:48:20 AM
Thanks for the input guys. Glad to see my issues aren't deal killers.

So, a safe at the shop? Should I put it right between the forklift and plasma cutter to make it real easy for them? Seriously though, can I store guns at the "mailing address"?

As for the kid at the shop, preschool would be a welcome option as soon as I can make enough to justify it. Kindergarten soon too! I tend to do most of my work that requires concentration after he goes to bed...

I guess for the moving around, we've decided not to move the machine shop again unless it makes sense financially. Changing the FFL address wont be the biggest problem... I guess if we end up overseas, I would just have to shut down the FFL and try to restart it upon returning.
DogtownTom  [Team Member]
1/11/2012 10:33:25 AM
Originally Posted By whiskeyjacked:
So, a safe at the shop? Should I put it right between the forklift and plasma cutter to make it real easy for them?

There is no requirement to have a safe.

Seriously though, can I store guns at the "mailing address"?

Sure, but you need to list that address with ATF

http://www.atf.gov/publications/newsletters/ffl/ffl-newsletter-2006-03.pdf
Q. Can an FFL ship a firearm to an address
that is different from the business
premises address identified on the
license?

Yes. Neither the GCA nor its implementing
regulations contain specific provisions,
requiring that an FFL have firearms shipped
to their licensed business premises when
receiving firearms. To that end, an FFL may
lawfully receive firearms at their mailing
address, storage location, or other address
where the licensee intends to ensure safe
and secure receipt of the firearms.

ATF Industry Circular 74-13 outlines
“Guidelines for Verifying Identity and
Licensed Status of Transferee.” It states, in
part, that “when the shipment is to be made
to an address other than the transferee’s
premises as listed on his or her license or on
his or her certified list, it is suggested that
the transferor verify the address as being
that of the transferee.” Furthermore,
pursuant to section 922 (b) of the GCA, it is
unlawful to ship a firearm interstate to an
unlicensed individual.

We encourage that FFLs verify to the best of
their ability that the shipping address is a
valid location where the licensee is prepared
to receive and subsequently possess the
firearms. In addition, if an FFL has customers
that require frequent delivery of firearms to
an address other than their licensed business
premises, we recommend that the shipping
address be placed on file with ATF’s Federal
Firearms Licensing Center (FFLC) as an
additional mailing address.

It should be noted that any FFL receiving
firearms at locations other than their
licensed premises must maintain accurate
records of acquisition and disposition of
firearms. The acquisition of firearms must be
recorded by the close of the following
business day or, if commercial records are
maintained, within 7 days following the
acquisition (See 27 CFR 478.125(e) and (g)).
In the event of an ATF compliance
inspection, the FFL must make all records
and firearms inventory available for
inspection. In addition, if the location is
used as a continuous off-site storage facility,
the FFL must notify the FFLC so that the
address can be placed on file
.

whiskeyjacked  [Team Member]
1/11/2012 12:14:03 PM
Awesome, thanks for finding that newsletter. I'll reference that if I need to.