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Posted: 8/19/2026 3:15:42 PM EDT
[Last Edit: kel][Edited]
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Ok, we all know that you can obtain GCA firearms to one's Sole Prop FFL and if you want to move one to one's "personal collection" vs. "business inventory" there's longstanding guidance on how to do that. ATF has long advised that genuine personal firearms kept at the licensed premises should be separated from firearms offered for sale, clearly identified as personal and not for sale, and supported by documentation showing personal ownership. It's best practice to tag it "not for sale" or "Display only" if it's remaining on FFL premises after you log it out of your A&D to yourself. No 4473 or NICS needed, because ATF considers "you" and the FFL to be one entity. But you still can log it out of your books to your "personal collection" so it's not confused with your inventory during an audit, etc. Now, same thing with a NFA/GCA silencer: even WITHOUT the with current Jensen v ATF situation, it seems like the same procedure applies. Properly log it out to your personal collection. No Form 4, no 4473, no NICS. It hasn't "changed entity hands" in a transfer – we merely want it to not be mistaken as business inventory and show it logged out to personal collection. Straightforward on how to record disposition in one's A&D books. But the question came up of how to remove it from one's eForms inventory. Ask The Experts provided this:  I hate AI, but this reply was smirk worthy:  Seems odd that you don't have to do any 4473 or F4 when transferring your stuff from FFL to Personal Collection when going out of business, but the Expert thinks you do when you are in business... :) ATF: "14.2.1 Sole proprietors. FFLs licensed as sole proprietors, who have been qualified to deal in NFA firearms and who go out of the NFA business, may lawfully retain their inventory of these firearms, including imported NFA “sales samples”, in their individual capacity. No NFA transfer occurs that would require an ATF-approved transfer because the firearms are still possessed by the same person to whom they were previously transferred and registered." Has anyone had experience during an audit or otherwise with doing / not doing a Form 4 on a personal NFA item? -and- My actual question for ATF: Has anyone found a method to remove the NFA item from their eForms inventory? |
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Originally Posted By KitBuilder: If you’re a sole proprietor, then you (as a person) and your business are the same thing. So there’s no transfer. “To personal collection” is the correct disposition. I believe we agree on this. However, no one can figure out how to get it out of eForms inventory. I don't want my personal items confusing anyone by showing up as business inventory, so yeah: I log it out of my books... but it's still on eForms. |
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Originally Posted By kel: I believe we agree on this. However, no one can figure out how to get it out of eForms inventory. I don't want my personal items confusing anyone by showing up as business inventory, so yeah: I log it out of my books... but it's still on eForms. 
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| Do what you think is right based on your reading of the regs. As long as it the item is truly in your personal possession and you can produce it if required the ATF inspectors can correct/advise you if needed at inspection time. A problem might arise if you transferred it to somebody else but if you actually still have it then it's a learning opportunity at worst. |
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Originally Posted By Bladeswitcher: A problem might arise if you transferred it to somebody else but if you actually still have it then it's a learning opportunity at worst. That's kind of what I was thinking: If I "transferred it to myself" and some IOI has a problem with that later down the road, kinda hard to say it changed hands, and the disposition is correctly noted in the A&Ds regardless. :) But the eForms and NTRFR is what would trigger the "hey, where is this?" during an audit. In my previous routine audits, ATF shows up with a list printed out from the Registry, says "We show you've got 2604 silencers in stock. Let's see them." But if one is now NOT in stock, but rather has been logged out to one's personal collection, no longer business inventory, there's got to be a way to get it reflected that way in eForms. And yes Señor Hansohn, I *could* try to do a Form 4. With my luck, the next "Expert" would reject it with a note that it's not necessary or possible to F4 from oneself to oneself. 
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Originally Posted By kel: That's kind of what I was thinking: If I "transferred it to myself" and some IOI has a problem with that later down the road, kinda hard to say it changed hands, and the disposition is correctly noted in the A&Ds regardless. :) But the eForms and NTRFR is what would trigger the "hey, where is this?" during an audit. In my previous routine audits, ATF shows up with a list printed out from the Registry, says "We show you've got 2604 silencers in stock. Let's see them." But if one is now NOT in stock, but rather has been logged out to one's personal collection, no longer business inventory, there's got to be a way to get it reflected that way in eForms. And yes Señor Hansohn, I *could* try to do a Form 4. With my luck, the next "Expert" would reject it with a note that it's not necessary or possible to F4 from oneself to oneself. ATF - "show us this silencer" Solprop ffl - "here in my A+D book, you can see it has been disposed to my personal collection and isnt in the actual inventory anymore." I imagine something similar will happen when all these dealers get audited after selling cans on a regular 4473. |
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Originally Posted By sarabeck404: How about a FA pre 1986 transferrable machine gun - same as a suppressor - out of A&D book to "personal collection"? No form 4 necessary ?? David The type of firearm matters not one bit. What matters is whether the licensee is a sole proprietor, an LLC, Corporation or Partnership. With a sole proprietor, the license is issued to a specific person. That person can also conduct business under an assumed name, "DBA" or trade name. The FFL will show both their name and their business name if they have one. If the FFL is issued to your corporation, with you as the Responsible Person on the FFL, everything in your A&D is in the possession of the corporation, not you personally. To transfer to your "personal collection" it would take a Form 4/4473/NICS. See page 3, Que #8 of the September 2013, Volume 2 - Federal Firearms Licensee (FFL) Newsletter |
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Yes, I already understand the sole prop. bit. I am a sole prop and have a FA in my inventory/a&d book and in eForms. I don't need to do a form 4, w/ fingerprints, etc. Just transfer it to myself? I also have a state where I live MG license. Seems too easy. AND, what about the $200 tax stamp ? That didn't go away like it did for suppressors, SBS's and SBR's ? It gets complicated, doesn't it? Thanks a lot, David |
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Originally Posted By sarabeck404: Yes, I already understand the sole prop. bit. I am a sole prop and have a FA in my inventory/a&d book and in eForms. I don't need to do a form 4, w/ fingerprints, etc. Just transfer it to myself? Originally Posted By sarabeck404: Yes, I already understand the sole prop. bit. I am a sole prop and have a FA in my inventory/a&d book and in eForms. I don't need to do a form 4, w/ fingerprints, etc. Just transfer it to myself? If your Form 3 or Form 4 has YOUR NAME OR DBA on it, its ALREADY transferred to you. I also have a state where I live MG license. Seems too easy. I have no idea what your state may require. AND, what about the $200 tax stamp ? That didn't go away like it did for suppressors, SBS's and SBR's ? If you are a sole proprietor you aren't transferring it, so no $200, no Form 4. It gets complicated, doesn't it? Not really. |
Plano, Texas...........the Gun Nut Capitol of Gun Culture, USA
https://www.youtube.com/watch?v=pELwCqz2JfE
https://www.youtube.com/watch?v=pELwCqz2JfE
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Originally Posted By sarabeck404: Yes, I already understand the sole prop. bit. I am a sole prop and have a FA in my inventory/a&d book and in eForms. I don't need to do a form 4, w/ fingerprints, etc. Just transfer it to myself? I also have a state where I live MG license. Seems too easy. There is no effective way "at this time" to move NFA off your license and into your personal collection like you can with non-NFA. Even if you follow the procedures, the NFA items are still listed in the NFTR, and come inspection time, the IOI will bring that list with them and want to see them. At least that is how it has worked for me for 30 years. |
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Originally Posted By RenegadeX: Even if you follow the procedures, the NFA items are still listed in the NFTR, and come inspection time, the IOI will bring that list with them and want to see them. At least that is how it has worked for me for 30 years. Yesterday, I got another reply from "Ask the Experts".... they said "You should contact your local field office." :D Which is a humorous punt. "We don't know how to get them off of your eForms inventory or the NFTR, so... kick that can down the road a bit and hope this guy stops asking us." |
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Originally Posted By RenegadeX: There is no effective way "at this time" to move NFA off your license and into your personal collection like you can with non-NFA. Even if you follow the procedures, the NFA items are still listed in the NFTR, and come inspection time, the IOI will bring that list with them and want to see them. At least that is how it has worked for me for 30 years. I have several SBR's/SBS's/silencers noted as "personal collection" in my bound books. In eighteen years no IOI ever asked to see one (five compliance inspections). |
Plano, Texas...........the Gun Nut Capitol of Gun Culture, USA
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Originally Posted By DogtownTom: I have several SBR's/SBS's/silencers noted as "personal collection" in my bound books. In eighteen years no IOI ever asked to see one (five compliance inspections). LOL as we probably have shared same IOIs. They always print out my NFA list when they come to visit, and want to inventory them. For the first few inspections, they consistently had things missing, mostly post samples - G18C, MP5, AK-47, etc. Each time we would update and they would come 3 years later and still not updated. It was finally correct after the last inspection 3 years ago. |
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Originally Posted By RenegadeX: LOL as we probably have shared same IOIs. They always print out my NFA list when they come to visit, and want to inventory them. Originally Posted By RenegadeX: LOL as we probably have shared same IOIs. They always print out my NFA list when they come to visit, and want to inventory them. They do that with me as well. Without me having to tell them, they just rattle off the dozen in my personal collection and we go on. Have never asked to see them. For the first few inspections, they consistently had things missing, mostly post samples - G18C, MP5, AK-47, etc. Each time we would update and they would come 3 years later and still not updated. It was finally correct after the last inspection 3 years ago. Remember the ShadowOps Weaponry debacle? I had a customer buy a "silencer" from that bankruptcy auction in 2015. The idiot dealer who was shipping the assets for the federal court in Colorado, Form 3'd to me, but mailed it to another dealer in Dallas who was out of business. It was returned to the original dealer by USPS. He didn't reship and didn't tell ATF that it was returned. It kept comong up in two compliance inspections. In 2020, Rebecca Sinclair managed to get it removed, but it reappeared on my list in 2024. I also had a Benelli SBS that was listed twice in my eForm inventory. It stayed that way for several years. NFA Registry is a hot mess. |
Plano, Texas...........the Gun Nut Capitol of Gun Culture, USA
https://www.youtube.com/watch?v=pELwCqz2JfE
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