Our previous alert of May 11, 2016, covered ATF. Rul 2016-1, which addresses the requirements for federal firearms licensees (“FFLs”) to maintain their acquisition and disposition records electronically rather than on paper. In this alert, we review ATF Rul. 2016-2.
ATF Rul. 2016-2
In this ruling, ATF addresses electronic versions of the Form 4473, Firearms Transaction Record. This is the form that must be completed when an FFL transfers a firearm to an unlicensed recipient. Regulations in 27 C.F.R. Part 478, Subpart H, require that FFLs prepare Form 4473 in paper form with handwritten entries. Rul. 2016-2 states FFLs are permitted to use software to prepare the Form 4473 without obtaining an approved variance, as long as certain requirements (summarized below) are met.
It is important to note that the holding of the ruling supersedes ATF Rul. 2008-3 and supersedes all previously approved variances covering the use of an electronic Form 4473. The changes …Read the Rest