With the start of the New Year comes a chance to embrace new habits and enact New Year’s resolutions. To that end, NSSF in partnership with FFL Unleashed, would like to offer four resolutions in pursuit of compliance excellence.
Resolve to Double Check: The first practice we offer is to have a second employee review all 4473 forms prior to the customer leaving the store with a firearm. Of the top 10 issues for which ATF cites FFL holders, eight are clerical errors on 4473 forms. Having a second employee step back and review the 4473 while you’re ringing up the sale is a quick way to ensure errors are caught and corrected prior to the customer leaving the premises. Once the customer leaves the store, correcting the errors become more time consuming and difficult.
Resolve to Double, Double Check: The next practice we offer is a dedicated resource to check all your forms and records from the day as part of standard end of business day process. This employee should be given extra training on compliance issues and the authority to correct errors uncovered. Forms reviewed should include all of 4473s, A&D book entries, any NFA forms, multiple handgun forms, and any denials to make sure no straw purchase took place. In stores where this dedicated resource is allocated, errors are nearly always caught and corrected long before ATF arrives.
Resolve to Inventory: The next practice we can’t recommend strongly enough – take a complete inventory of your firearms! If you aren’t doing this on a scheduled basis, at least do so annually. When you take the inventory, make sure to compare the existing inventory to the opens in your A&D Book and vice versa. This will insure your inventory and your A&D entries are correct and you’ve identified any potential missing firearms.
Taking an inventory does a number of things for your store besides providing peace of mind all your firearms are accounted for. Taking routine inventories helps to deter internal theft. Further it ensures any firearms that have gone missing are researched sooner rather than later. It’s much easier to trace the path of a firearm a month after it’s missing than a year later. And finally, when the ATF comes for an inspection, it’s much better if you’ve taken the time to find missing firearms, correct your records, and report missing firearms to ATF and the local authorities.
Resolve to Train: The final practice we’d like to offer is during each of your staff meetings you review a compliance topic. This topic can be taken from review of the week’s work, from talking with a compliance officer, or from reviewing a portion of the white book. Regardless of where this information comes from, by dedicating time to this review, it shows you, the owner/manager, are vested in the compliance process and how important these practices are to the success of your business.
National Shooting Sports Foundation stands ready to help you on all compliance best practices. For more compliance tips and tactics, please visit nssf.org/retailers.
Director, Retail Development
National Shooting Sports Foundation