To go from a type 1 FFL Dealer with SOT, to a type 7 MFR with SOT, is there any way to do it without having to get a new FFL number and sending in all my logbooks to ATF?  

Previously I learned that is what happens if I upgrade to be an MFR:
https://www.ar15.com/forums/armory/How-convoluted-is-switching-from-type-1-SOT-dealer-to-Type-7-MFR-Screwed-up-last-SOT--/44-526591/

Two reasons I really don’t want to change my license number:
1- My state charges $125 a year to be a dealer, and it is tied to my FFL number.  So I would need to to that again, as it renews at a different time.  Or maybe I would need an all new (2nd) state license as well, at least for the first year.

2- I just don’t want to deal with the hassle of moving everything over to a new set of books, then not having access myself to my old transfers and paperwork (while ATF will have them all).  What if they say I messed up the paperwork on a transfer- missed a box, whatever- and I don’t have a copy?  They certainly are not going to go out of their way to make me copies of anything I need.  Also I have done a lot of transfers to myself, and the 4473’s are my best records showing what I have, and when I acquired it.  Keeping a copy of everything would be a lot of photocopying for sure.  

3- I would rather destroy old 4473’s at 20 years than send them in all in for digitizing- no reason to give all that info for their backdoor registry that isn’t a “register”.  I know ATF is trying to make everyone send in all 4473’s instead of destroying them at 20 years, but hopefully they get some pushback on that...  I don’t have anything that old for a few years yet, but would rather stretch out the type 1 lifespan and pay a few extra years to keep it, vs making it easy on them.  


So what is the answer?  Maybe just maintain the type 1 FFL, move any class 3 stuff onto a new type 7 and stop getting the SOT on the type 1?  But then this makes it so I would need a state license on the type 1, and on the type 7.  Maybe move all new incoming business to the type 7, and just maintain the type 1?  Or will ATF demand I close it out if I am not doing actual transfers with it.  And if I do transfers on it, the state will want their yearly license fee...

Hopefully this makes sense.  Seems like there has to be a simpler way but I am not seeing.  I would seriously rather pay an extra $150 every three years than have to photo copy all of my 4473’s and logbooks to keep a copy for myself.  What a hassle.  At the same time, I sure don’t want to pay for a 2nd SOT every year, nor a 2nd state license every year.  Do people/businesses hold more than one type of FFL at a time, and does it make sense to do so?  

Any insight would be appreciated.  

As you must be aware, the FFL type is part of the License number.

No.
You don't switch, you don't "upgrade" or convert......you get a wholly new and distinct type of FFL with its own number.





Likely no way around that.




They aren't YOUR records, you just maintain them for ATF.



If you turn in your records and ATF comes back in six months saying you forgot to sign a 4473....they'll show you the form.



Nothing stops you from running your own 4473's through a copier. But if I were a customer and found out you were making and keeping copies of 4473's that you turned over to ATF out of business records......I'd be pissed. You have no need to keep a customers 4473 forever.
Again, whoever told you ATF Form 4473's were for keeping track of your personal firearms needs his head pulled out of his butt.



So don't give up your 01. Since you ran 4473/NICS on yourself I'm assuming you are a corp or LLC, not a sole proprietor. Just incorporate a new business that will hold the 07FFL.



How does $125 affect your bottom line? Its part of doing business.



You are the first FFL I've ever heard that wants to make copies of his old FFL's. They aren't business records, they're ATF records.

You have more faith in ATF’s good intentions than I do.

And I have worked with them professionally a lot more than I have dealt with them as an FFL...  So my opinions are based around that.  Well that and all the stuff in the news, their constantly changing opinions, obvious desire to put some people out of business, etc... you get the idea.  


Appreciate the feedback though