Talked to mine. He's a mom & pop shop/gunsmith/supressors/cerakote/etc.... Says they're going to stay open for smithing, but aside from the $1k mo. limit they're just going to do transfers.

Apparently they can do as many transfers as they want. Didnt know that. Dont know what kind of living one can make from just that, but I imagine it'll keep some home based FFLs in business?

All about volume. Usually less than 15min on the phone for a $50 transfer. And yes, keeping paperwork for a few years. They can probably do enough to pay for the FFL fee.

I don't think revenue from transfer sales is exempt from the $1,000/mo limit. I think it all counts (guns, transfers, accessories, ammunition, etc.)

So at $1,000/mo, you are looking at 20 to 50 transfers depending on how much one charges.  Expect transfer prices to go up as available options decrease.  Besides, as a business owner looking at a cap of $1,000/mo, do I want to do 20 transfers for my $1,000, or 50?  Can't make it up with volume in this case....

And I can say from experience, a transfer is a minimum of 30 minutes, more like 45, these days.  It takes longer to get the information entered into the WSP system, printing out applicable forms to sign, plus the fact they have to come back in 10 business days to pick it up (counting that in the 30-45 minute portion).  Old days, I could get a non-chatty-kathy in and out in 10 minutes for everything but pistols, plus whatever time I spent sending out FFL copies, waiting for packages, opening boxes, processing, recycling, etc.  

From the first contact (Hey, I bought a gun, can you send your FFL to XYZ Guns?) to them actually taking it home, I figure it's an hour of work.

I would say $15 is applied to the $1k mark. They might get under the radar through transfers though since it isn't a sale.
Definitely transfers are not fast. They have to meet the customer twice due to the uodated illegal registry system doesn't give a instant approval.

It's a "sale" in my accounting software.  Admittedly under the "service" heading as opposed to "retail" for B&O tax purposes, but still a "sale".  When I run a profit&loss report out of quickbooks, transfer fees are under the "ordinary income" sub heading.....

I get what you mean. I have to deal with that too.

RCW 9.41.010:

(38) "Sale" and "sell" mean the actual approval of the delivery of a firearm in consideration of payment or promise of payment.

(48) "Transfer" means the intended delivery of a firearm to another person without consideration of payment or promise of payment including, but not limited to, gifts and loans. "Transfer" does not include the delivery of a firearm owned or leased by an entity licensed or qualified to do business in the state of Washington to, or return of such a firearm by, any of that entity's employees or agents, defined to include volunteers participating in an honor guard, for lawful purposes in the ordinary course of business.

If the FFL does not own the firearm, then they have nothing to sell. If all the FFL does is transfers, those are done without a sale. Therefore, transfers are exempt from the $1000 threshold. At least how I read it.

Naturally, they didn't think this through.

This bunch isnt known for penning the legislation they copy-pasta from other sources, so whatever they pass isn't exactly steeped thought-provoking endeavor.

You think the AG is going to think that way?  Good luck. They’ll cross-reference every UBI an FFL has with their Department Of Revenue reports (monthly, quarterly or annual, depending on volume.). The bill doesn’t say “$1,000 per month average of direct sales of firearms.”  It “$1,000/month in sales”. The courts will go with the most common definition of “sales” from DOR regulations, which will include transfer fees.  “Services” are sold, meaning it is SALES. Oh, and ammo, accessories, gunsmithing services, etc.

Regardless, there isn’t enough transfer business out there to keep all of us afloat, especially since the vast majority thinks it should be free or no more than $20.