I am considering starting a FFL inside of a existing business. A appointment only type of set up. No items on display. No one would know a FFl exist there until they inquire about it. There would be a simple web site listing prices and items but nothing crazy.

My main draw is trying to better serve the NFA community in my area. I would like to offer low rate transfers on suppressors and MGs with the flexibility of me providing the buyers visits to their toys.

I am hoping to charge $35 per NFA item and possibly less if I can become a bronze & silver dealer.

I am located in a very small town but would serve a 25-30 mile radius which includes some really large towns. I am in GA and the area I am in is pro gun with alot of shooters.

I am kinda on the fence about the whole thing once tallying up the cost. A Safe, SOT, FFL, LLC etc...

I am needing some more figures/estimates to see if its worth going forward with.

I know the following questions will be dependent of the size of business. So just answer the best you can.

So how many NFA transfers are you guys doing a year?
Do you charge for range visits?
Does the range have to be at your physical location of business?
What type of suppressor inventory are yall carrying for a smaller shop?
Is Silencer Shops distributor price better or worse than other distributors?
How many Non NFA transfers do you do a year?

How much is your insurance on your inventory? I did not consider that.

I wasn't planning on doing a large number of MGs if any.  And would charge more for the transfer on them just due to the room they take up in a safe.

And as far as the range visits go, it would be a once a month or every other month affair. We have a local outdoor range that I could work with, I am friends with the owner. It would help him get some traffic and let my customers play with their cans. My idea would be to notify the buyers of a range visit day and if they want to go they will need to let me know in advance. If no one lets me know then No range day.

I am wanting to clear a flat $10 per transfer. So I would have to do 50 firearm/NFA transfers a year just to make up on my SOT tax.  I would have to do 80+ transfers a year or $800 worth of sales/transfers to start showing a profit. And thats not counting insurance so probably more like $1000. Now this will be a side business that I could operate while getting paid at my main occupation at my main occupation. So the possibility of doing some online NFA sales (F3 to other FFL) is not out of the question.

Also what is the rules on selling yourself a suppressor? If I own the LLC and my Trust buys 1-2 suppressors from my LLC a year would that cause any type of issues? of course all NFA fees apply. I just remember reading somewhere that 01 FFl is not for expanding ones collection or something similar.

Do you still have to do ITAR?  If so that's a huge increase before you break even.

I have not been able to find the final rules they were working on yet, so I assume they have not published them yet.  From what I have heard, it could reduce the cost of doing substantially.

I really appreciate your honesty and answers. Your helping me paint the picture of how much really goes into owning a shop.

The insurance that you have can you change it throughout the year depending on your inventory or is it locked in for a year?

What do you consider a fair profit per suppressor? Main reason for the $10 is to be competitive with the other guy who is charging $50 and I know $25 of that is going to SS for the F4. I was thinking of charging $35 per transfer which would include the SS F4 fee and leave me pocketing $10. If I sell/order more suppressors from SS that would drop and my profit margin would go up slightly.

As far as expenses all I would have would be the FFL (yearly $66.00), SOT $500, City License $50, Insurance?, maybe $100 in random things for the business (paper, files, stamps etc..) That is not counting the initial cost of the safe and LLC paper work. Looked it up yesterday the LLC should run about $300. And the safe is whatever you want to spend.

I have applied for my 03FFl a few weeks back just to have. I figured it would be a good learning experience if I wanted to start my own 01 in a year or so.

Concerning the (LLC FFL owner) selling cans to the Owners personal trust. The reason I was considering that situation would be the case if their was a deal on a suppressor that I was wanting personally to keep forever. In case I let the SOT go or sell the business.  I understand that anything on the FFL books is eligible to be used by the owner / responsible parties.

Which leads me to my next question.

Do guys who own FFLs whether it be a sole or LLC get the SOT just to use as a way to get suppressors sent directly to the shop to "demo" for a while (1-3 years) then sell off to another SOT or individual? I guess you could look at it as a lease. I know you would have the initial cost of the can which would be wholesale (cheaper than individual buying from a dealer)  but no $200 tax. Or would that be tax evasion?

In my area of NE Georgia if a line is drawn directly North of Buford GA to the NC line and East of Buford to Elberton GA & the SC line there are a number of SOTs. Out of all of them I am only aware of 1 that has reasonable NFA transfer prices which is $50. The 2 that are in my county charge $125 and $75 last I checked. One of these shops went out of business but did not close down all the way ??? very weird situation and would never use them for a NFA transfer.  The other shop is the more expensive of the too and they have a spotted past. To my knowledge only 1 other FFL is in my area and he is not a SOT. He is a good guy and charges $10 for firearm transfers. It is who I personally use. I dont see him in operation in the next 5 years or so as he is slowing down and getting ready to retire. But I could be wrong.

I thought ITAR only affected gunsmith and manufacturers?

And I thought they recently cut that portion out on gunsmith and a manufacturer had to  do so much in sales or production before they were hit. Could be 10000% wrong on that.

Either way if its required that puts the death nail in my FFL side business.

It was my understanding that you had to have it with your SOT at one point.  It's worth checking.  Isn't it $2,500 / year?   I know at one point some SOTs were ignoring the ITAR requirement if they weren't doing something that required it, then they got tougher and I know of several people who got out due to the cost, and I think that's the reason for it.

We will all have to wait and see how it affects who and in what way.

The Proposed change was published back in May and I have not heard since then.

Proposed Changes Published.

There are several links in this small article, including one to download a .pdf on the proposed changes.

Another link to the NRA-ILA article as well

NRA-ILA article

ITAR has nothing to do with SOT. An SOT is simply a flat annual tax allowing someone to engage in the NFA business as a dealer or as a manufacturer without being taxed on each firearm.

ITAR registration is currently required for those who manufacture or perform manufacturing operations for items listed on the US Munitions List.
What the State Dept. DDTC considers as "manufacturing" or "manufacturing operations" is not the same as what ATF does.

I know.   I simplified it because I had been told by SOTs that they were told they had to pay ITAR to keep their license and SOT.   It's worth mentioning it as something to consider.  $2,500 / year is huge if you didn't budget for it on a small business.

If a customer comes to me wanting me to receive a silencer he bought from out of state or off GunBroker, I'll charge $50. I'll complete my part of his Form 4 and give him an easy to follow checklist of where he needs to sign/date and what he needs to do next (prints and photos that the buyer can do himself for free) along with FBI FP cards. If he prefers to have SS process the Form 4.....I charge $25 because that's what Silencer Shop will charge me. To me, $50 is a fair fee.

So if one of your customers transfers an out of NFA purchase to you and request the SS F4 then the total price would be $75?

Do you have an alarm system? Yes the business we are in has alarm and video.

Does your state charge sales tax on firearm transfers? (Texas doesn't but some do) I think in Ga services are exempt at least in the line of work I am in we do not pay tax on our professional services.

While I have sold a couple of lightly used silencers to a customer, most want brand spanking new since they are paying a $200 tax for the privilege and waiting up to a year.
I have no idea how much suppressors cost wholesale from a distributor but is their enough gap to give a buyer a decent price break on a demo can? I guess it would depend on MSRP and MAP.


Looking at what as a lease? Any transfer of an NFA firearm from an FFL/SOT to another person via Form 4 will require $200

Yes I am aware of that, I did not word that properly. Let me give a example.

Guy likes suppressors/NFA items. He creates a FFL as a sole proprietorship and pays SOT. He then uses the FFL/SOT license to buy new suppressors/SBRs/SBS at wholesale pricing  for "demo"aka personnel use.The FFL/SOT enjoys them for months, years etc and then sales them off. OR keeps them and discontinues the SOT at that point transfers them into his own collection NFA F4 $200 tax paid.

Tax evasion may not be the best words to describe the above example. But is the example I listed above ok to do according to the BATF?

Also can responsible persons be in possession of FFL/SOT inventory away from the store?
Example: LLC owns the FFL/SOT and the LLC has 2 Responsible persons listed with the ATF. Could RP1 stay manning the store and RP2 be out at the range/hunting club with a client demoing a product?

And can Responsible Persons have/store FFL/SOT inventory at their residence away from the store?

Correct.

Typically demo cans from a manufacturer are sold to the dealer at a discount, with the provision that they not be resold to the public.
If you buy a silencer at wholesale from a distributor, use one, then sell it to a customer you can price it how you want.

Giving a "decent price break on a demo can" is not going to help your business and will get you blacklisted by the manufacturer. MAP policies differ between manufacturers, with some letting your sell for less than MAP, but you can't show less than MAP on a price tag, signage, "in the cart" or using language like "buy one get one free". Some manufacturers enforce their MAP vigorously, others will not.

Firearms acquired by an 01FFL/SOT who is a sole proprietor are "his". The FFL is issued to him, in his name and most often a business name (DBA).
When the sole proprietor decides to turn in his FFL or keep his FFL and stop paying SOT...…….he keeps those NFA firearms. He does not file a Form 4 because he, personally, is in lawful possession. The exception would be any post '86 machine guns.

Sure. As can bonafide employees.

Is the RP a business partner? If not......don't make them an RP, but an employee.
Responsible Person as pertains to FFL licensing- In addition to a Sole Proprietor, a Responsible Person is, in the case of a Corporation, Partnership, or Association, any
individual possessing, directly or indirectly, the power to direct or cause the direction of the management, policies, and practices of the Corporation,
Partnership, or Association, insofar as they pertain to firearms.
Not all employees would have that kind of authority.

Sure, as can employees. They can even take it out of state. (otherwise you would never see guns at SHOT or the NRA Show.
But be aware its an easy way to lose track of items and could be difficult to explain at a compliance inspection. "Oh, those five silencers and the two SBR's are with Bob who's out of town on vacation"...…...likely won't float. It's not a good practice IMO. Way to easy for an RP or employee to be sloppy with his caretaking and your insurance may not cover locations other than your own.

You should not get an FFL if that is all you want to do. I doubt you would get called on it, since in your books it will show inventory in, inventory out, but your intent does not seem to be in the business. I used the above model 15-20 years ago, except I really did demos and those demos resulted in sales. I then sold off the demos as they became less popular.

This brings us to something not yet mentioned - be ready to change. 15-20 years I was easily in the top 3-4 silencer sellers in the USA. And I did not want to be. I just wanted to sell local. But as internet word got out I had inventory, in some cases the only dealer with inventory for a certain model, I got calls from all over the USA. Eventually 99% of my inventory was going out on F3 not F4. So I went from local dealer with maybe $10K in demos, to quasi-wholesaler with $100K or more in inventory. And now I am back to being a local dealer with 99% of my sales via SilencerShop. So be ready to change to market situations.

When Anna was "out in the country".

Just some truck stop on the way to Oklahoma..... One of the few communities to have a greater than 1:1 silencer to resident ratio, and they did not even know it.

Wow did not realize that. Makes my previous questions kinda dumb.

So if a sole proprietor lets his SOT and FFL go is there a stamp to show legal ownership of the suppressor or SBS,SBR?

I agree with you. Not trying to start a FFL to do my above example.

Main reason is to provide guys in my community with another option when it comes to NFA transfers and firearm transfers. I enjoy the NFA aspect of gun ownership and would like to make it a small side business. While doing so I was hoping to personally get some good deals as a fringe benefit. Mainly reduced transfer fees and having the ability to enjoy my purchase while waiting for a stamps approval.

I had no idea a FFL could keep NFA items that were on the books as personal items upon closer of the business.

If your plan is to have an FFL/SOT, etc so you can play with MG’s personally and not realy be in business. Just look like it..? A good chance you are  going to have issues with ATF. From their POV..there is very little middle ground. You are either actualy in business and working it as such or you are a private individual.
Do not forget...you have to have local, city, county, State business and zoning signed off before ATF will approve it.

No, but there is a Form 2,3,5,etc with his name on it, unless he acquired the gun from a non-SOT, and then there is a F4/Stamp.

Yes, even pre-may dealer samples.

My local ffl (silencer shop affiliate) Only charges me $25 for the transfer of the can. Is that abnormally low?

Yes I have been told that was very frowned upon by others. I have a personal MG and plan on buying a few more transferable MGs over the years.

That was another reason for wanting my own SOT/FFL is having the ablity to have a MG I purchase in hand while the F4 clears.

And since this is going to be inside my current business the zoning shouldn’t be a issue. Our town is less than 500ppl. I personally know everyone one on the city council, and boss is on the city council and vice mayor. I used to serve on the DDA.

From my calling around in my area yes. You have a awesome FFL.

For a silencer bought through Silencer Shop he cannot charge you ANY FEE.

If its for a can you didn't buy from Silencer Shop I would question his business acumen......that's a very low fee for something he may store for a year.

Holy hell you want to transfer at $35 AND include the $25 SS fee? For a $10 gross profit?

You'll be out of business in less than a month.

I'm curious, how are you going to recoup your cost after spending over $10,000 on the kiosk and supporting livescan equipment? Pay taxes, insurance, storage, licensing, not to mention your time etc.

Yup.

Sounds like that guys FFL is screwing him.

No Kiosk / Live scan

Taxes will be what they are. So $500 + sales.

Insurance is a big I dont know. Going to have to look into it more.

Storage. Will most likely be my safe at home. I am planning on getting a larger one for the house and will bring my old one to work.

I am still up in the air on the SOT. I am looking harder at just doing the FFL first. But this is still all in the exploratory stage. And I may not do anything.

I think the poster was referring to a F3 transfer from an out of state shop to his local FFL. A non SS purchase.  And if that FFL/SOT is doing enough business thru Silencer Shop then the transfer paper work on his end could be done for $5 by SS. So a $20 profit on the FFL/SOTs part. Or his FFL is doing the paper work in house and letting the buyer do the leg work on prints and photo and pocketing the whole $25.

The Pre may dealer samples are they only able to be sold to other FFLs/SOTs by FFL/SOTs?

And is that considered a Keeper?

I have seen the Keeper lingo used on MGcentral and never fully understood what made it a keeper.

Also what type of process does a FFL have to go thru to become a Public safety/ blue gun dealer?

All I can say is $10.00 profit will not keep you in business very long, the gun business in all segments is a very competitive cut throat business!

Keeper means you can keep it after you give up license. They can only be xferred to other FFL/SOT, but obviously you do not havr to have an FFL/SOT to sell one (since you gave it up). In that case it is a F4 xfer. Pre-May is not just MG, but any imported NFA after 1968 (for MGs, and before 5/19/86).

Thanks Renegade for the information.

You and Dogtowntom both have been very helpful.

I need to talk to my FFL that I have been using. He has been in business for 15+ years and always charged $10 for transfers on guns. He has a small shop at his house. He does carry a very slim inventory of guns less than 10. He offers limited gunsmithing (trigger jobs, cleaning, mounting scopes, fixing stocks) and carries a small amount of ammo. And has done well with it as a side business.

I need to see how long he plans to be in the business and what type of numbers he is doing on sales & transfers. He is such a good guy I wouldn't want to step on his toes and most likely wouldn't if I felt that my FFL would hurt his business.

Your normal FFL guy is doing well because he has no overhead.  Very little invested and has a established himself since he has been doing it for X amount of years.

He has a hobby.  Not a business.  He does not make his income from it.

I charge considerably more than $35 for an NFA transfer. As stated, you’re sitting on it for upwards of a year.