ATF Publishes Three Rulings on Recordkeeping – Part 3 of 3

By Justin Stakes

Washington, DC -(AmmoLand.com)- This alert is the final of three installments reviewing ATF’s recent rulings on recordkeeping. Our previous alerts of May 11 and May 12, 2016, covered ATF. Rul 2016-1 and Rul. 2016-2, respectively.

In this alert, we review ATF Rul. 2016-3.

ATF Rul. 2016-3

This ruling addresses two separate record keeping issues. The first is consolidation of records of manufacture and records of disposition. The second is how to record changes to firearms that have already been logged into the acquisition and disposition records. Both issues were previously addressed in ATF Rul. 2010-8, which is now superseded and replaced by ATF Rul. 2016-3.

Current ATF regulations in 27 C.F.R. Part 478, Subpart H, require licensed manufacturers to maintain records of their manufacture or other acquisition of firearms separate from their records of firearm dispositions to nonlicensees. ATF Rul. 2016-3 allows consolidation of these two types of records as long as the following conditions are met (our comparison of ATF Rul. 2016-3 to ATF Rul. 2010-8 indicates virtually no changes as to the conditions for consolidation …Read the Rest

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