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Posted: 5/2/2017 7:31:33 PM EDT
| Is it standard practice to save the fax or email confirmation after receiving it from the ATF of CLEO? I just had an inspection and the IOI stated I should save the confirmations and staple them with the 4473 and the MDF. |
| Never heard of a CLEO confirmation either. However, it is a good idea to print the ATF confirmation - just don't keep it with the 4473. It is not a required record - therefore it's none of the ATF's business unless you need to prove that you sent a particular form that they say they never received. Then, you can go see if you have the confirmation. By keeping the records separate, and therefore off limits to the ATF, it doesn't look like you failed to send one in if you forgot to print the confirmation for one form. |
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In nearly nine years of being an FFL, at least five multiple sale forms every week, NEVER have I received a confirmation back from ATF.
And I doubt any of you have either. What you got was a confirmation from your fax machine that the transmission went through....it's a setting on your fax machine. |
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Try emailing it sometime. You get a confirmation back from a real person. Quoted:
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In nearly nine years of being an FFL, at least five multiple sale forms every week, NEVER have I received a confirmation back from ATF. |
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Why do I want or need a confirmation? No regulation requires one. Quoted:
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Try emailing it sometime. You get a confirmation back from a real person. No regulation requires one. |
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You're right. However, it's a CYA. During an inspection, the ATF sometimes claims that a multiple sales form was never sent in. It's your word against theirs unless you have some proof. Quoted:
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Why do I want or need a confirmation? No regulation requires one. 
At each of my compliance inspections the IOI's had a printout of my multiple sale forms and matched them with the appropriate 4473. When they found a 4473 and its multiple sale report that was not on the printout guess what happened?.........NOT A DAMN THING. They just asked if I could make another copy for them to take with them. Big deal. It's not even a requirement to fax or email the report. Snail mail is perfectly acceptable......and they don't mail back a confirmation for that either. |
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Try emailing it sometime. You get a confirmation back from a real person. No regulation requires one. |
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Which doesn't address the fact that a confirmation is not required, not needed or in any way "helpful" to the licensees recordkeeping requirements. If the ATF ever questioned whether a report was sent I have the ability to search when it was sent and the receipt back. Do whatever works for you. |
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What confirmation from what CLEO?
My boss shreds 'em when someone brings us one, same as multiple gun sales and FFL and C&R license applications and renewals. If we have the record here, it becomes an "open record". The boss shreds em as soon as he sees em. We can't provide records we don't have |
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What confirmation from what CLEO? My boss shreds 'em when someone brings us one, same as multiple gun sales and FFL and C&R license applications and renewals. If we have the record here, it becomes an "open record". The boss shreds em as soon as he sees em. We can't provide records we don't have I've heard through the grapevine that my CLEO also round files them. I still send them over though. |
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CYA?
At each of my compliance inspections the IOI's had a printout of my multiple sale forms and matched them with the appropriate 4473. When they found a 4473 and its multiple sale report that was not on the printout guess what happened?.........NOT A DAMN THING. They just asked if I could make another copy for them to take with them. Big deal. It's not even a requirement to fax or email the report. Snail mail is perfectly acceptable......and they don't mail back a confirmation for that either. |
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Which doesn't address the fact that a confirmation is not required, not needed or in any way "helpful" to the licensees recordkeeping requirements. Quoted:
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Try emailing it sometime. You get a confirmation back from a real person. No regulation requires one. However, I have personally seen saved confirmations be helpful to avoid violations in inspections. |
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I did a couple multiple sale forms last month. The only reply I got back (I sent it by email) was a happy cheery reply back from some girl saying "thank you"
That's it. That being said that was the copy sent to the Atf. The Cleo I haven't received back jack ever. From FFL licensing, change of address, or multiple sale form. Nothing |
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The only reason I asked was that they were missing two multiple disposition forms when the IOI conducted my compliance inspection. I had the copies attached to the 4473s, but the IOI didn't see them on her report. IOI asked me to fax them to the ATF tracing center again and print out a copy of the fax confirmation. Turns out that was a violation even though I had a copy of the 4473, but I had no proof of sending it in.
Turns out this was an inspection from hell. She checked out my 4473's for the past year which came out about 150 and she stayed at my house for two complete 8 hr days. |
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The only reason I asked was that they were missing two multiple disposition forms when the IOI conducted my compliance inspection. I had the copies attached to the 4473s, but the IOI didn't see them on her report. IOI asked me to fax them to the ATF tracing center again and print out a copy of the fax confirmation. Turns out that was a violation even though I had a copy of the 4473, but I had no proof of sending it in. Turns out this was an inspection from hell. She checked out my 4473's for the past year which came out about 150 and she stayed at my house for two complete 8 hr days. Glad you shared though so that others see how important of a CYA this can be. |
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The only reason I asked was that they were missing two multiple disposition forms when the IOI conducted my compliance inspection. I had the copies attached to the 4473s, but the IOI didn't see them on her report. IOI asked me to fax them to the ATF tracing center again and print out a copy of the fax confirmation. Turns out that was a violation even though I had a copy of the 4473, but I had no proof of sending it in. Turns out this was an inspection from hell. She checked out my 4473's for the past year which came out about 150 and she stayed at my house for two complete 8 hr days. |
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No ATF regulation requires a licensee to have "confirmation" that you faxed, emailed or snail mailed the multiple sale form. Any IOI that says this is bullshitting you. |
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No ATF regulation requires a licensee to have "confirmation" that you faxed, emailed or snail mailed the multiple sale form. Any IOI that says this is bullshitting you. Quoted:
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The only reason I asked was that they were missing two multiple disposition forms when the IOI conducted my compliance inspection. I had the copies attached to the 4473s, but the IOI didn't see them on her report. IOI asked me to fax them to the ATF tracing center again and print out a copy of the fax confirmation. Turns out that was a violation even though I had a copy of the 4473, but I had no proof of sending it in. Turns out this was an inspection from hell. She checked out my 4473's for the past year which came out about 150 and she stayed at my house for two complete 8 hr days. However, if the ATF says that you failed to send it in (which is a regulation), then having proof that you sent it in would be nice to have. As I mentioned, I've seen multiple citations for "failure to send a form in" (just like what happened above). Every IOI is not as easy going as yours. Clearly this is an issue for some FFLs. Not sure why you're so against some folks keeping confirmation of something when it has repeatedly helped some of those that do it and has hurt some of those that don't. Your experience has been different - we get it. It isn't required - we get it. The fact remains, if the OP had confirmations, he wouldn't have received violations because he could prove he sent it in. Because this situation is similar to many others I've seen, I'm going to recommend that FFLs get confirmations because I'm looking out for their best interests and I want to keep them out of trouble. Not sure what your motivation is trying to fight that. |
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It's not "CYA"......it's paranoia. Quoted:
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That sucks. Sorry that happened. Glad you shared though so that others see how important of a CYA this can be. I've officially spent too much time arguing about my free advice to help FFLs. I've stated what has helped other FFLs and the failure of which has hurt some FFLs (including the OP) - time to move along. |
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Again, you're right. I don't see anybody disagreeing with you that you can snail mail it in and that confirmation is not required. However, if the ATF says that you failed to send it in (which is a regulation), then having proof that you sent it in would be nice to have. As I mentioned, I've seen multiple citations for "failure to send a form in" (just like what happened above). Every IOI is not as easy going as yours. Clearly this is an issue for some FFLs. Not sure why you're so against some folks keeping confirmation of something when it has repeatedly helped some of those that do it and has hurt some of those that don't. Your experience has been different - we get it. It isn't required - we get it. The fact remains, if the OP had confirmations, he wouldn't have received violations because he could prove he sent it in. Because this situation is similar to many others I've seen, I'm going to recommend that FFLs get confirmations because I'm looking out for their best interests and I want to keep them out of trouble. Not sure what your motivation is trying to fight that. Quoted:
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The only reason I asked was that they were missing two multiple disposition forms when the IOI conducted my compliance inspection. I had the copies attached to the 4473s, but the IOI didn't see them on her report. IOI asked me to fax them to the ATF tracing center again and print out a copy of the fax confirmation. Turns out that was a violation even though I had a copy of the 4473, but I had no proof of sending it in. Turns out this was an inspection from hell. She checked out my 4473's for the past year which came out about 150 and she stayed at my house for two complete 8 hr days. However, if the ATF says that you failed to send it in (which is a regulation), then having proof that you sent it in would be nice to have. As I mentioned, I've seen multiple citations for "failure to send a form in" (just like what happened above). Every IOI is not as easy going as yours. Clearly this is an issue for some FFLs. Not sure why you're so against some folks keeping confirmation of something when it has repeatedly helped some of those that do it and has hurt some of those that don't. Your experience has been different - we get it. It isn't required - we get it. The fact remains, if the OP had confirmations, he wouldn't have received violations because he could prove he sent it in. Because this situation is similar to many others I've seen, I'm going to recommend that FFLs get confirmations because I'm looking out for their best interests and I want to keep them out of trouble. Not sure what your motivation is trying to fight that. If your IOI threatens you with failing to comply.....why not yank out a copy of your phone bill. Mine shows every fax call to ATF and I can pull the same call history from my fax machine. I'm not fighting anything other than paranoia. 
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