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Posted: 10/25/2009 6:09:17 PM EDT
About this time last year, someone asked the total cost of getting an FFL with SOT. Someone in response mentioned that all SOTs must pay an annual ITAR fee. someone else said that it isn't required by the BATFE and it is not a requirement. Did we ever find out if it is required?
Link Posted: 10/25/2009 6:18:51 PM EDT
[Last Edit: 10/25/2009 6:21:20 PM EDT by RenegadeX]

Originally Posted By bulletsponge13:
About this time last year, someone asked the total cost of getting an FFL with SOT. Someone in response mentioned that all SOTs must pay an annual ITAR fee. someone else said that it isn't required by the BATFE and it is not a requirement. Did we ever find out if it is required?

It is not a requirement for an FFL/SOT to register with ITAR. The majority are not required to. Only those that manufacture defense articles must register. That is a very small percentage of FFL/SOTs.
Link Posted: 10/25/2009 6:32:45 PM EDT
If you are just an FFL (type 1 or 2) with an SOT (Type Class 3 aka dealer only) you do not need to pay the ITAR fee.

However, if you are a firearm manufacturer (type 7 or 10) with (Class 2 SOT) or not, than you will need to pay the ITAR fee regardless of whether you have ever or ever plan to export anything.

Are there folks out there who are Title 1 FFL firearm manufactuers and/or a FFL firearm manufacturer with a Class 2 SOT who have never paid the ITAR fee... sure, but they just have not been caught yet.

However, if you are a manufacturer FFL (type 7 or 10) and make anything that could be construed as a defense article that is on the United States Munitions List than by the letter of the law you need to register and pay the appropriate ITAR fee. (in most cases $1750 per year if memory serves correctly)

Hope this helps

James
Austin, Texas
Link Posted: 10/25/2009 6:43:15 PM EDT
Originally Posted By jbntex:
However, if you are a manufacturer FFL (type 7 or 10) and make anything that could be construed as a defense article that is on the United States Munitions List than by the letter of the law you need to register and pay the appropriate ITAR fee. (in most cases $1750 per year if memory serves correctly)


It went up to $2250 last year just to register, and I've heard from the folks who do export stuff that those fees increased as well.
Link Posted: 10/26/2009 5:38:33 PM EDT
Originally Posted By Bubbles:
Originally Posted By jbntex:
However, if you are a manufacturer FFL (type 7 or 10) and make anything that could be construed as a defense article that is on the United States Munitions List than by the letter of the law you need to register and pay the appropriate ITAR fee. (in most cases $1750 per year if memory serves correctly)


It went up to $2250 last year just to register, and I've heard from the folks who do export stuff that those fees increased as well.


Correct, just went thru an SOT licensing inspection.
Link Posted: 10/27/2009 5:55:23 AM EDT

Originally Posted By TheOtherDave:
Originally Posted By Bubbles:
Originally Posted By jbntex:
However, if you are a manufacturer FFL (type 7 or 10) and make anything that could be construed as a defense article that is on the United States Munitions List than by the letter of the law you need to register and pay the appropriate ITAR fee. (in most cases $1750 per year if memory serves correctly)


It went up to $2250 last year just to register, and I've heard from the folks who do export stuff that those fees increased as well.


Correct, just went thru an SOT licensing inspection.

A What? There is no inspection for SOT. Are you saying you sent in SOT payment and they came out to inspect your premises before issuing you your SOT?
Link Posted: 10/27/2009 1:21:36 PM EDT
[Last Edit: 10/27/2009 1:33:14 PM EDT by timpryor]
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Link Posted: 10/27/2009 1:30:08 PM EDT
he probably ment his FFL. there is an inspection for that, not for the SOT.
Link Posted: 10/27/2009 1:38:22 PM EDT
[Last Edit: 10/27/2009 1:39:23 PM EDT by RenegadeX]

Originally Posted By timpryor:

My SOT here in San Antonio had to have an inspection before they would give him his SOT I thought this was SOP

He probably changed license types when he got his SOT.
Link Posted: 10/28/2009 2:24:54 AM EDT
They do a premis inspection when you get an FFL for the first time and also explain the forms and record keeping reqirements to you.
The normal compliance inspection is for FFL holders, but if you are also a Class 3 they can also check those items at the same time.
Been there done that - many times. I've had an FFL/Class 3 for 33 yrs.
Sarge
Link Posted: 10/29/2009 5:24:20 PM EDT
Originally Posted By RenegadeX:

Originally Posted By timpryor:

My SOT here in San Antonio had to have an inspection before they would give him his SOT I thought this was SOP

He probably changed license types when he got his SOT.


Nope, my employer got his 02 manufacturers license. They sent 2 agents for the inspection/document dump at the place of business. One of them was hot too..
Link Posted: 10/29/2009 5:33:21 PM EDT

Originally Posted By TheOtherDave:
Originally Posted By RenegadeX:

Originally Posted By timpryor:

My SOT here in San Antonio had to have an inspection before they would give him his SOT I thought this was SOP

He probably changed license types when he got his SOT.


Nope, my employer got his 02 manufacturers license. They sent 2 agents for the inspection/document dump at the place of business. One of them was hot too..

Not sure what this random tidbit has to do with an FFL/SOT in San Antonio.
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