Multiple Long Gun Sale Reporting: Border States

[ExecDirector]

Integrally suppressed rifles are made from what used to be "normal" Title I rifles. When they are turned into NFA items, the serial number of the original rifle is recorded in the "additional information" section and the serial number of the tube becomes the serial number "of record." So far so good.

I create three integrally suppressed semi-automatic weapons, one in .223, one in .308 and one in 9mm, out of semi auto rifles and carbines. I properly report their manufacturing to NFA Branch. Customer shows up and wants to buy all three. We fill out his Form 4's and send $600 off to Martinsburg. Six months pass and all three Form 4's come back approved and I tell the guy to come pick up his stuff. He does and he fills out the 4473 all right and proper. Still so far so good.

The question is: Since I am an FFL/SOT in Texas, do I have to fill out a multiple long arm sale report? They have become NFA items, but they are still semi-auto rifles...

The answer is: If you are selling the rifles using an 01 or 02 license (Dealer or Pawnbroker) then you would need to complete the rifle multiple sale form in Texas. If you are selling them using a Type 07 (Manufacturer), 08 (Importer), 10 (Manufacturer DD) or 11 (Importer DD) licensee then the requirement to complete the form 3310.12 does not apply. Importers and Manufacturers are exempt from the reporting requirement.

[ExecDirector]

FYI, This came directly from ATF, ESD.

[BWE Firearms]

All I can say is WOW. Does ATF intend to make everything as confusing as possible. I would hate to be in your shoes when ATF comes to do a compliance inspection, there is no telling what they are going to say.

[ExecDirector]

Richard,
You do not know the half of it! I have three FFLs at this address. A My own 01/Sot, my 07/SOT, and the 01/SOT for the NFATCA. And although this is Texas, the county is Harris, which has pretty much never had a CLEO sign a NFA Form. So the IOI's are not nearly as experienced with NFA as one would hope. And because this is Texas, each FFL is required to have a yearly compliance inspection. I've taken it as an opportunity for teaching.

When an audit occurs, I clear off the big giant table, put down a copy of the NFA Handbook, the appropriate bound book and corresponding 4473 files, a really large print set of instructions to my gun tagging system... and ask them if they would like coffee, soda, juice or water. I usually wind up having to walk them through the vagaries of NFA such as how to find the correct serial number on an integral, why the NFRTR doesn't match my inventory, etc. When all is said and done, they usually walk away with a bit more knowledge than when they started. I give them my NFATCA business card and tell them to feel free to call me if they have questions...

I suppose it could be worse.

[BWE Firearms]

Don't you love having to teach the ATF the rules they made up before you can talk to them about it. It drives me nuts every time I have to do it.