eForms Error Correction Process

[ExecDirector]

Many users of the eForms system have noticed that there are significant errors in their NFRTR inventory, as reported by eForms. Often, the information in eForms does not reflect the correct information evidenced by a Form 3 (as an example) in hand. It is common for a manufacturer or model name/number to be incorrect in eForms when it is correct on the Form in hand. ATF has confirmed that this is a "coding error" and that the NFRTR is actually still correct. This situation is problematic for a variety of reasons:

1) eForms does not allow the user to make modifications to the various fields describing firearms.
2) eForms provides a significant approval time advantage over paper/fax.
3) Submitting eForms applications with known errors has the potential to perpetuate known errors.

When an eForms user encounters known errors and wishes to submit a transfer application he/she can:

1) Revert to paper/fax and submit the application correctly, with the extended wait time assumed.
2) Submit the eForms application with errors and notify NFA Branch of the errors after approval has been received.
3) Preemptively attempt to correct the eForms entries using the following procedure:

• Identify the error
• Confirm that the inventory listing does not match the approved Form in hand
• Notify NFA Branch of the error in writing (or email?)
• Await confirmation of correction
• Process eForm application

Obviously, none of these approaches is ideal. The data that exists in the eForms system should already be accurate and reverting to paper should not even be a consideration. Further, there should be an online option for submitting correction requests. Unfortunately, there is no current budget to upgrade or improve the eForms system and all are being forced to make do with a less than perfect system.

[ExecDirector]

Just as an FYI... It would appear that the eForms portrayal of users' NFA inventory is quite likely dropping hyphens/dashes that are part of serial numbers. Approved eForms have these special characters deleted in the serial number box. This apparently programatic deletion of data would appear to be in direct conflict with ATF's direction that all special characters, including hyphens, be recorded as part of the serial number to facilitate tracing. "Symbols, numbers, and/or letters found in firearm serial numbers often identify model designations and date of manufacture and may include other coded manufacturer data and are often very important to a successful trace of a crime gun."

More news as we learn more.

[ddnc]

I have had several eform applications that had errors of various types and I have had to have direct communication with Gary Schaible to enter certain models/Mfg's that are not in the NFA drop down registry. The new entries were in the system within 30 minutes and some of the larger errors, a couple which resulted in disapprovals were corrected and approved within 24 hours. They have actually been very responsive and apologetic in all instances. I'm not sure if this addresses the previous post contextually so apologies if this is the case.

[ExecDirector]

It *is* helpful. We are learning that a lot of this is the fault of "coding errors" made while porting the NFRTR to eForms. Gary is very helpful, but the system should not have to rely on one person to correct a mountain of errors only after they are "caught."

eForms is broken and needs to be fixed.

[sillycon]

From a software developer perspective, I can pretty much promise you that the issue isn't REALLY "coding errors"; it's much more likely that someone was cut corners and/or didn't take the time to understand what the requirements of the system are. The removal of the special characters was a deliberate choice made by someone, and was most likely a "quick fix" to an error that was found while storing those characters in the database. Sadly, this sort of thing is all too common as doing it the "right way" (by escaping the character(s)) is much more involved and time consuming.

As a separate thought, given the level of access to data required to build such an application, it should be a trivial matter to get simple counts of transferable items in the NFRTR.

Then again, that data in the wild could really shake up the NFA market. Imagine what would happen if people found out that there were, in fact, only 300 "X"'s when people thought there were tens of thousands, and in fact 1,000 Y's when only 5 were thought to exist. Oh my!

[ExecDirector]

To government... The euphemism for cutting corners and piss poor follow through is "coding errors." <sigh>

[jason8844]

As a separate thought, given the level of access to data required to build such an application, it should be a trivial matter to get simple counts of transferable items in the NFRTR.

Then again, that data in the wild could really shake up the NFA market. Imagine what would happen if people found out that there were, in fact, only 300 "X"'s when people thought there were tens of thousands, and in fact 1,000 Y's when only 5 were thought to exist. Oh my!

It would never happen. I tend to think that even with the lowball estimates, the numbers of MGs might be enough that a lawyer could argue that they are "in common use" as defined by Heller and deserve 2A protection and therefor overturn the '86 ban. The anti-gunners could not risk it even with the low odds.

[sillycon]

My point wasn't that that was possible in an "official" capacity, but perhaps in an unofficial one just to have an idea of what is, in fact, out there.

I see SO much speculation about numbers "there's only one/two of these on the registry" or "there's tens of thousands of those on the registry", etc. Some are relatively easy to confirm (like SWD M11/9's -- one manufacturer with production records on a firearm that was sold almost exclusively to the civilian market) but other things such as M16's have SO many manufacturers that it's nearly impossible to know with any level of reasonable certainty how many there are. Ditto DIAS, etc.

I've seen transferable count (gu)estimates as low as 120k, and as high as 180k. I don't think either of those would be enough to be considered "common use", however.

[jason8844]

I've seen transferable count (gu)estimates as low as 120k, and as high as 180k. I don't think either of those would be enough to be considered "common use", however.

I have heard estimates double that. However, I have no idea how they came up with the number. Even if MGs were off the table, it could make a case for suppressors, SBRs and SBSs. I know it is still a pipe dream though.

[ExecDirector]

Last time we got an aggregate number of transferable MG's from ATF they claimed in the 182,000 range.