First Atf Inspection.... - Page 1

[ARCHIVED THREAD] - First Atf Inspection....

Posted: 12/6/2018 2:24:36 PM EDT

Finally got the call. After about 3 years in business the time has come. We try to do everything by the book, but I know we've made a few mistakes on our 4473 forms over the years. Hopefully they won't be too hard on us.

What has others experienced when the Atf finds 4473 form mistakes or A&D book mistakes?

Posted: 12/6/2018 4:36:14 PM EDT

[#1]

If it's like my inspections went, they'll mostly just note if you have small paperwork errors, and instruct you on things to double-check. Which really you should be doing anyway.

I guess their notes go into their report, and in future inspections, they might move up to citing you if the errors persist, which could eventually result in a fine or penalty or loss of license.

Mostly they want to see that your A&D book matches your physical inventory, and anything that was disposed of has the proper outgoing paperwork. If you have any Title 2 inventory, they'll probably start there, then move on to the Title 1 stuff (which they won't already have a list of).

Missing inventory or grossly errant paperwork might result in more severe actions, but I never had those issues.

Posted: 12/6/2018 4:51:43 PM EDT

[#2]

Quoted:
Finally got the call. After about 3 years in business the time has come. We try to do everything by the book, but I know we've made a few mistakes on our 4473 forms over the years. Hopefully they won't be too hard on us.

What has others experienced when the Atf finds 4473 form mistakes or A&D book mistakes?

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Fix your mistakes before they show up.

Posted: 12/6/2018 5:04:24 PM EDT

[#3]

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Fix your mistakes before they show up.

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We are doing an internal audit right now. But some things like a missed customer signature can't be fixed.

Posted: 12/6/2018 5:07:59 PM EDT

[#4]

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But some things like a missed customer signature can't be fixed.

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Yes they can, the process is explained in the instructions.

Posted: 12/6/2018 5:10:16 PM EDT

[#5]

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Quoted:
We are doing an internal audit right now. But some things like a missed customer signature can't be fixed.

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When I worked retail we'd call the customer and explain that we made a mistake and have an ATF audit coming up. Asked if they would come in and help us out. Most were happy to help. Everyone had their own style but I just simply told them we goofed up on the paperwork and missed something and anytime they could make it in and correct it, it would be greatly appreciated. I always drove the point home that there is no time limit, whenever at all was convenient and I never threatened. Despite the internet toughguy routine, I never once had someone demanded freebies or I pay their gas. Of course if it was a big mistake that could have caused serious issues I'd offer them a free box of ammo or a gift card to incentivize them to show up sooner rather than later. Besides when they came in, free box of ammo or not, maybe 50% of the time they bought something.

Posted: 12/6/2018 6:44:08 PM EDT

[#6]

Oh, I know how I'm supposed to fix them. Just short of having the customer come back, those can't be fixed.

Yeah, we can call the customer, if we have their number, have them fix it. Hopefully they can come in time. It's our mistake for not checking, just hoping we don't get a big fine or our license pulled. Most are small clerical errors, or filing errors.

Posted: 12/6/2018 7:03:14 PM EDT

[#7]

Routines and procedures go along way.

IE, if you've got mistakes, what training do you have in place to keep the employees / staff from making those mistakes again.

How are new employees trained?

Even rudimentary procedures or on boarding training is helpful in showing you're being proactive in compliance.

Posted: 12/6/2018 7:53:08 PM EDT

[#8]

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Quoted:
Routines and procedures go along way.

IE, if you've got mistakes, what training do you have in place to keep the employees / staff from making those mistakes again.

How are new employees trained?

Even rudimentary procedures or on boarding training is helpful in showing you're being proactive in compliance.

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We are a small mom & pop shop. It's just myself and wife. I'm working really hard on keeping her on track, and not being too upset when mistakes are made. We need help, but as we just opened a new store, trying to get past that new store rush and justify hiring an employee. It doesn't help that I have another business that keeps me from the store 4-5 months out of every year.

Posted: 12/6/2018 7:55:38 PM EDT

[#9]

I have seen stores that have laminated 4473 forms with all of the instructions and a John Doe mock up so that employees have a reference form to refer to when working with a customer. Now a lot of stores that are using computer based software, they go through the form with the customer and someone else double checks the form on the computer before it is submitted.

But as was said, just make sure you have a proactive system for fixing or catching errors before submission and that someone or somehow you have a double check system in place.

Posted: 12/8/2018 2:54:58 PM EDT

[#10]

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But some things like a missed customer signature can't be fixed.

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But some things like a missed customer signature can't be fixed.

I don't comprehend how a licensee misses getting the customers signature on the 4473. You need to establish a procedure where the 4473 is checked, checked again and then re-checked BEFORE the gun leaves the shop or you won't be in business come your next renewal.

Posted: 12/8/2018 4:52:30 PM EDT

[#11]

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I don't comprehend how a licensee misses getting the customers signature on the 4473. You need to establish a procedure where the 4473 is checked, checked again and then re-checked BEFORE the gun leaves the shop or you won't be in business come your next renewal.

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I agree becuase if its a consistent problem with no corrective action they have cause to take action.
You're fortunate they called. I had ATF just show up unannounced no phone call, they can an will do that. I'm small potatoes. He had to come back again for some reason can't recall I think he had to ask his supervisor a question. Or it could be we talked a lot? Supposedly, as an FFL we are supposed to be helping them by keeping excellent records at all times. My experiences with ATF and FBI have been respectful and positive along with informative as well.
Let us know how it went.

Posted: 12/8/2018 5:27:49 PM EDT

[#12]

The first inspection I had was such b*******. The inspector was good for the first day on the second day he tried to get me on a manufacturing log issue. He said I didn't follow the format when in fact there is no stated format. You just have to have a certain information and I had all that information plus some which help me to tie together the form to with the form 4.

He backed down when I pointed out that the NFA registry was wrong where it had me in possession of a short-barreled rifle that had been transferred months ago to the customer.

Posted: 12/8/2018 6:19:00 PM EDT

[#13]

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Quoted:
The first inspection I had was such b*******. The inspector was good for the first day on the second day he tried to get me on a manufacturing log issue. He said I didn't follow the format when in fact there is no stated format. You just have to have a certain information and I had all that information plus some which help me to tie together the form to with the form 4.

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MFG format is specified in 478.123(a)- 478.123(d) of the CFR. It implies columns, but does not specify that. Is that what you mean? I know folks who do one page per gun and have all the info, just not in columns.

Posted: 12/9/2018 1:57:18 PM EDT

[#14]

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Quoted:
MFG format is specified in 478.123(a)- 478.123(d) of the CFR. It implies columns, but does not specify that. Is that what you mean? I know folks who do one page per gun and have all the info, just not in columns.

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Quoted:
The first inspection I had was such b*******. The inspector was good for the first day on the second day he tried to get me on a manufacturing log issue. He said I didn't follow the format when in fact there is no stated format. You just have to have a certain information and I had all that information plus some which help me to tie together the form to with the form 4.

MFG format is specified in 478.123(a)- 478.123(d) of the CFR. It implies columns, but does not specify that. Is that what you mean? I know folks who do one page per gun and have all the info, just not in columns.

Yes it was in columns. I had more information than shown in the CFR. Felt that he felt obligated to write me up for something. I told him that if he was going to write me up for that which I was obviously complying with I would have to make a big deal of the fact that the NFA registry had me in possession of a rifle that they had approved a form 4 for 6 months earlier.

He called his boss they spoke for a while and the next thing I know he dropped his demand to write me up for the manufacturing log LOL.

Posted: 12/12/2018 10:31:02 PM EDT

[#15]

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Quoted:

I don't comprehend how a licensee misses getting the customers signature on the 4473. You need to establish a procedure where the 4473 is checked, checked again and then re-checked BEFORE the gun leaves the shop or you won't be in business come your next renewal.

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I remember the transaction.... I checked the front carefully, and my wife that helps run the store, filled out the remainder of the form. As she was doing that, I was running the E-check. Customer passed, I wrote down the ntn and checked the box, and did my signature. At the time, we hadn't done very many, and was trying to get in a system.

In 3 years we have only found 6-7 mistakes on about 600 forms.