ATF 2016-1 & 2016-2

Gun StoreMaster is ATF 2016-1 & ATF 2016-2 Compliant

ATF authorizes licensed importers, licensed manufacturers, licensed dealers, and licensed collectors to maintain their firearms acquisition and disposition records electronically, provided all of the following conditions are met:

Gun StoreMaster exceeds all requirements listed in ATF 2016-1 & 2016-2. Gun StoreMaster generates form 4473 Transferor's Transaction Serial Numbers (TTSN#) and can generate unique numbers which guarantees that you will not have a duplicate TTSN#.

1. The licensee records in the computer system all of the acquisition and disposition information required by 27 CFR 478.121, 478.122, 478.123, 478.125(e), 478.125(f), and 27 CFR 479.131, as applicable. Required information includes a record of both the manufacturer and the importer (if any). Additional columns can be utilized to capture certain additional information (e.g., inventory number, new/used, etc.), so long as the additional information is separate from the required information and the required information is readily apparent. An ATF Form 4473 serial number may be used instead of the address for recording the transfer of a firearm to a non-licensee if such forms are filed numerically.

Gun StoreMaster tracks ALL bound book actions with a complete audit trail, while retaining the originally recorded information when changes are made to entries.

2.The electronic acquisition and disposition bound book software must track corrections and changes utilizing one of the following methods of tracking changes: a. The system must retain any correction as an entirely new entry, without deleting or modifying the original entry. When the software generates the bound book, the system must be able to quickly and easily change views of the bound book as follows:

1. Only view the original entries;

2. Only view the corrected entries; and

3. View both the original and corrected entries in the same bound book.

OR

b. The system must be able to print the corrections as a separate report containing the same parameters as are required for a paper bound book, including the firearm information, acquisition details, and disposition details. The format of the correction report may follow the traditional bound book format, or may be presented in any column format as long as the necessary information outlined above exists in the report (which may include a notes column).

OR

c. If a spreadsheet program (e.g., excel) is being utilized, the system must be able to track any edits/corrections/amendments in a “notes” column. Any edits/corrections/amendments may overwrite the original entry so long as the “notes” column explains any edits/corrections/amendments and/or tracked changes (i.e., what was changed, who made the change, and why the change was needed).

The Gun StoreMaster electronic bound book format allows you to manage your firearm records and filter them out efficiently by transaction type, status, firearm type, NFA/Title II, etc.

3. The system cannot rely upon invoices or other paper/manual systems to provide any of the required information. Also, if a licensee chooses to use an electronic recordkeeping system for any of its required acquisition and disposition records, then all acquisition and disposition records, regardless of type (e.g., gunsmithing, sales, NFA), must also be in the electronic format as prescribed by this ruling.

Our comprehensive search system goes above and beyond the ATF's requirements for records searchability.

4. The system must allow queries by firearm serial number, acquisition date, name of the manufacturer or importer, name of the purchaser, address of purchaser or other transferee, and ATF Form 4473 transferor’s transaction serial number (if any).

Gun StoreMaster subscriptions include our InStore™ automated bound book back up program, eliminating the need to remember to download or back up your A&D records. Don't worry, InStore™ will take care of that for you.

5. The licensee must download all records from the system to a physical storage device (e.g. hard drive, Compact Disc (CD), Digital Versatile Disc (DVD), or Universal Serial Bus (USB) Flash Drive) at the licensee’s business premises, or print and maintain them at the licensee’s business premises: a. at least semiannually; however, if the records are downloaded, from a host facility (e.g., remote server or cloud storage provider) contracted/leased by the licensee as provided in condition #9, they must be downloaded at least daily. In all cases, the records must be downloaded in a format that is unencrypted with the required information readily apparent; b. upon request of an ATF officer (must be provided within 24 hours); c. prior to discontinuance or change of: the software (program); the database system, whether or not maintained by a host facility (e.g., remote server or cloud storage provider); and/or the host facility (if applicable); and d. prior to discontinuance of the licensee’s firearms business. The downloads/printouts must include all firearms in inventory, as well as all firearms transferred during the period covered, sequentially by date of acquisition, and must be limited to display only the information required by the applicable regulations. The downloads/printouts may contain additional columns capturing certain additional information, provided that the required information is readily apparent.

6. If a licensee downloads the records onto a physical storage device (e.g., hard drive, CD, DVD, or USB Flash Drive), the download must be retained on the physical storage device until the next download is prepared. Additionally, the licensee must be able to present the most current version of the requested records in a printed format at ATF’s request.

7. If the licensee prints out the records, the printout must be retained until the next printout is prepared.

Gun StoreMaster offers a special 'Antique' firearm type allowing you to keep your antique firearms recorded in your program, and keeps them secluded from your Title I and Title II firearms to organize your firearms.

8. Downloads/printouts may include antique firearms, but cannot include other merchandise. However, antique firearms must be identified as such in the “firearm type” column.

Gun StoreMaster InStore™ allows you to record your records locally, and our cloud servers are based within the United States, and if we plan to change facilities our customers will be among the first to be notified.

9. Electronic firearms acquisition and disposition records may be stored on a computer server or device owned and operated by the licensee, or contracted/leased by the licensee through a host facility (e.g., remote server or cloud storage provider), provided that: a. The firearms acquisition and disposition records are readily accessible through a computer or device located at the licensed premises during regular business hours; and b. The licensee’s server is located within the United States or its territories, or if a host facility is used, that facility must have a business premises within the United States or its territories, and must be subject to U.S. legal process. Licensees are strongly encouraged to ensure that there are proper and robust security protection measures in place (e.g., encryption) to ensure all data is protected.

10. If the licensee contracts with, leases from, or changes a host facility (e.g., remote server or cloud storage provider), the licensee must, within 30 days, notify his/her respective ATF Area Office of the name and address of the host facility.

Each Gun StoreMaster account is maintained separately per FFL license. If you hold multiple FFLs, you can maintain multiple Gun StoreMaster accounts to manage each license you hold.

11. Each licensee must maintain its firearms acquisition and disposition records on a separate/partitioned database that cannot be intermingled with the records associated with another license.

When something is recorded to Gun StoreMaster, it is automatically backed up in our secure cloud service, and Gun StoreMaster InStore will back up the same records locally in near real-time as well.

12. The storage system must back-up the firearms acquisition and disposition records on at least a daily basis to protect the data from accidental deletion or system failure.

13. Licensees must retain all records in accordance with 27 CFR 478.129, ATF Rul. 2010-8, Consolidation of Required Records for Manufacturers, and ATF Rul. 2011-1, Consolidation of Required Records for Importers (as applicable). It is strongly recommended that upon reaching 20 years, those electronic firearms acquisition and disposition records be either permanently maintained by the licensee or forwarded to the ATF Out-of-Business Records Center for preservation.

Gun StoreMaster gives users the ability download all acquisition and disposition records as a .PDF, .XLS, or .CSV (ASCII) file at any time with a few clicks of a mouse.

14. Upon discontinuance of business, the licensee must send required records to the ATF Out-of-Business Center in accordance with 27 CFR 478.127. The licensee must print out the required records or download them to a physical storage device (as defined in paragraph 5) or, at the discretion of the licensee, both. The complete printout or download must provide an American Standard Code for Information Interchange (ASCII) text file (in conformity with industry standards) containing all acquisition and disposition records, and a file description. The complete printout or downloaded ASCII text file (and file description) must contain all information prescribed by regulation. The NTC converts these files into image files not searchable by name.

Source: https://www.atf.gov/firearms/docs/ruling/2016-1-requirements-keep-firearms-records-electronically

Gun StoreMaster fast4473™ gives you the power to save time, stay organized, maintain compliance, and reduce employee labor expenses when managing your 4473 forms. Don't waste another minute on deciphering messy handwriting.

According to ATF 2016-2: ATF understands that using computers to complete the ATF Form 4473 saves time and money in bookkeeping and auditing expenses. Most businesses computerize inventory, sales, customer lists, and other business records. Permitting for electronic completion of the ATF Form 4473 while a customer is present at the business premises is convenient for both the licensee and the purchaser and may also facilitate better accountability of inventory and reduce the potential for recording errors on the ATF Form 4473. Therefore, ATF finds that there is good cause to authorize a variance from the requirements of the Federal firearms regulations as they relate to completion of the ATF Form 4473.

ATF also finds that, provided certain conditions are met, the alternate method set forth in this ruling is consistent with the provisions of 27 CFR 478.102(d), 478.121, 478.124, and 27 CFR 479.131 because the same required information will be captured on the electronic Form 4473. Further, this alternate method is not contrary to any provision of law, should not increase costs to ATF, and should not hinder the effective administration of the regulations.

Held, pursuant to 27 CFR 478.22, 478.102, 478.121, 478.124 and 27 CFR 479.26 , ATF authorizes an alternate method or procedure to the ATF Form 4473 (5300.9) requirements of 27 CFR 478.102(d), 478.121, 478.124, and 27 CFR 479.131. Specifically, ATF authorizes licensees to use an electronic ATF Form 4473 (5300.9) provided all of the following requirements are met:

fast4473™ makes it easy to follow requirements laid out by the ATF under 2016-2:

fast4473™ acts as your own Form 4473 software, no need to use cumbersome downloaded blank forms, or clunky e-forms 4473 from the ATF.

1. The licensee will follow the Notices, Instructions, and Definitions governing the use of the OMB-approved version of the ATF Form 4473, and either: (a) acquires and uses his/her own electronic Form 4473 software; or (b) downloads from ATF’s website and saves to his/her computer ATF’s most current electronic version of Form 4473, known as ATF e-Form 4473.

All 4473 notices, instructions, and definitions are easily accessed for both dealer, and customer users alike.

2. The e-Form 4473 displays clearly, on the same screen, or upon mouse-clicking a conspicuously displayed screen item, all of the Notices, Instructions, and Definitions contained on the current Office of Management and Budget (OMB) approved ATF Form 4473.

Filling out a new fast4473™ session each time a customer is going to transfer a firearm not only maintains compliance, but also allows you to capture the customer's most up-to-date information every single time.

3. The computer software must allow for a new e-Form 4473 to be created and completed upon each transaction. The system cannot populate Section A from previous transfers from the same transferee (buyer).

On the current version of the ATF Form 4473, the buyer answers questions for section B using the type of electronic device that you choose for your operation. Gun StoreMaster is a very hardware friendly system, so you don't need to be boxed into specific types of devices.

4. The transferee (buyer) of the firearm(s) must answer the questions for Section A of e-Form 4473 while physically present at the seller’s premises (to include a qualifying gun show or event). The questions presented on the computer screen must be legible, and contain the same wording as the current OMB-approved version of ATF Form 4473 (5300.9), Firearms Transaction Record. Where Form - 4 - 4473 requires “checking” or “marking,” the transferee may mouse-click in an appropriate box to answer the question on the e-Form 4473. Where Form 4473 requires “printing” or “handwriting” the transferee may enter the information on the e-Form 4473.

Our user friendly dealer entry process, customer entry process, and Firearms Transaction Record Review is simple for customers of all tech experience level to navigate the form review, and certification e-signature process. This allows flexibility for electronic signatures. Use touchscreen, mouse, or Topaz signature pad input when applying signatures to the 4473.

5. The e-Form 4473 must allow the transferee to review and amend his/her answers until he/she selects or mouse-clicks a statement on the screen that he/she “agrees with and certifies” the same transferee certification statement as the current OMB-approved ATF Form 4473 (5300.9). Once the statement has been selected or mouse-clicked, the transferee can no longer make revisions to his/her answers.

6. The transferee (buyer) confirms his/her answers with his/her signature and date on the form, certifying that his/her answers are true, correct, and complete, and that he/she has read, understood, and complied with the conditions, notices, definitions, and instructions for the form.

7. The transferor (seller) of the firearm(s) enters the information into the licensee’s computer for Section B and Section D of the e-Form 4473. The questions presented on the computer screen must be legible, and contain the same wording as the current OMB-approved version of ATF Form 4473.

fast4473™ allows flexibility for electronic signatures. Use touchscreen, mouse, or Topaz signature pad input when applying signatures to the 4473.

8. The transferee and transferor signatures on the e-Form 4473 may be electronic signatures captured via an electronic signature pad prior to printing or may be handwritten (ink) signatures on the printed copy of the e-Form 4473.

9. If the electronic signature pad breaks or fails to operate properly, the licensee must discontinue use of electronic signatures and obtain handwritten (ink) signatures on the OMB-approved ATF Form 4473 or the printed copy of the eForm 4473.

10. If the transferee (buyer) cannot read and/or write, another person, excluding the licensee or any employee of the licensee, may complete the answers. Two persons, other than the licensee or any employee of the licensee, must then sign as witnesses to the buyer’s answers and signature. The person who cannot read and/or write may electronically sign or mark the e-Form 4473. The two additional persons’ signatures must be handwritten in ink on the printed e-Form 4473.

11. All NICS or State POC related information must be entered accurately on the eForm 4473 in the applicable fields. These entries can be made via electronic population (auto-population of the fields) or manual electronic entry (typing the information into the fields). They may also be handwritten onto the form after it is printed.

Gun StoreMaster WebAssist Chrome browser extension works hand in hand with fast4473™ to quickly and accurately populate 4473 information over to the FBI NICS LEEP portal submission page.

12. In order to electronically populate information related to the NICS background check, the FFL must contact the FBI NICS or appropriate State agency to request - 5 - authorization to transfer specific NICS data from e-Check into the computerized system.

fast4473™ contains built in protocols for handling NICS/POC State check exemptions for qualifying permits, Brady Law transfers, and NFA transfers.

13. Pursuant to 27 CFR 478.102(d) and 27 CFR 478.131(a)(2), if an exception to the NICS or State POC check exists, the licensee must record such information on the ATF Form 4473 (i.e., if a transferee possesses a NICS or State POC exempt permit) in the applicable fields.

Download .PDF a copy of any 4473 form with a couple clicks.

14. If the licensee wishes to maintain e-Forms 4473 for pending transactions, the forms must be downloaded from the system to a physical storage device (e.g., hard drive, Digital Versatile Disc (DVD), server) at the licensee’s business premises, or printed and maintained at the licensee’s business premises: a. At least daily, in a format that is unencrypted with the required information readily apparent; b. Upon request of an ATF officer (must be provided within 24 hours); c. Prior to discontinuance or change of: the software (program); the database system, whether or not maintained by a host facility (e.g., remote server or cloud storage provider; and/or the host facility (if applicable); and d. Prior to discontinuance of the licensee’s firearms business.

15. If the licensee wishes to maintain e-Form 4473 for pending transactions, the forms may be stored on a computer server or device owned and operated by the licensee, or contracted/leased by the licensee through a host facility (e.g., remote server or cloud storage provider), provided that: a. The e-Forms 4473 are readily accessible through a computer server or device located at the licensed premises during regular business hours. b. The e-Forms 4473 documenting a pending transaction must be printed out upon request by any ATF officer. c. The e-Forms 4473 documenting a pending transaction must be searchable by the transferee’s (buyer’s) last name, address, and by firearms information, such as by serial number, manufacturer, and importer (if applicable). d. The licensee’s server is located within the United States or its territories, or if a host facility is used, that facility must have a business premises within the United States or its territories, and must be subject to U.S. legal process. e. Each licensee must maintain its stored e-Form 4473 on a separate/partitioned database that cannot be intermingled with another licensee’s records. f. The storage system must back-up the stored e-Form 4473 on at least a daily basis to protect the data from accidental deletion or system failure. - 6 - g. Licensees are strongly encouraged to ensure that there are proper and robust security protection measures in place (e.g., encryption) to ensure all data is protected.

16. If the licensee contracts with, leases from, or changes a host facility (e.g., remote server or cloud storage provider), the licensee must, within 30 days, notify his/her respective ATF Area Office of the name and address of the host facility.

fast4473™ allows a quick Firearms Transaction Record Review before prompting your customer to add their electronic re-certification signature to the 4473.

17. If the transfer of the firearm(s) takes place on a different day from the date that the transferee (buyer) signed Section A, the transferee must complete Section C immediately prior to the transfer of the firearm(s). The computer software cannot allow the electronic signature to be automatically populated in the form from a previously captured signature or information in the software.

Print your completed 4473 forms on-demand, along with an auto-generated Transferor’s/Seller’s Transaction Number to give you an easy to organize filing system.

18. The e-Form 4473 must be printed, including instructions, at the time the transfer of the firearm is complete and prior to the transferee departing the business premises. The transferor must verify that the signature and date are present and in the appropriate fields on the printed ATF Form 4473.

19. In the case of “denied,” no sale or cancelled transactions, the ATF Form 4473, including instructions, must be printed and the printout retained pursuant to 27 CFR 478.129(b).

20. If the transaction is not completed within 30-day period after initially contacting NICS, the ATF Form 4473, including instructions, must be printed and the printout retained pursuant to 27 CFR 478.129(b).

21. The licensee must print all ATF Forms 4473, including the Notices, Instructions and Definitions, on 8 1/2” x 11” white paper. The pages must be stapled together. The entire printed ATF Form 4473 must be a verbatim/exact image of the current OMB-approved ATF Form 4473 (5300.9). Each response to a question must be legibly printed and aligned in the particular space or box allotted for that question on ATF Form 4473. If the licensee is unable to print the ATF Form 4473, he/she must use the current hardcopy of the OMB-approved version of the form. The pages may be printed either single-sided or double-sided.

22. The licensee must retain the printed ATF Forms 4473 at the licensed premises in accordance with 27 CFR 478.124(b) and 129.

Source: 
https://www.atf.gov/firearms/docs/ruling/2016-2-%E2%80%93-electronic-atf-form-4473
https://www.atf.gov/rules-and-regulations/brady-law#:~:text=The%20Brady%20Law%20imposed%20as,handgun%20to%20an%20unlicensed%20individual.