Thread: C&R License
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Unread 04-23-2018, 08:54 PM   #12
Bill_in_VA
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Doom and gloom from the new guy FFL.
I've had a C&R FFL for 22 years now. I have had one compliance inspection in those 22 years and it was more because he literally happened to be in the neighborhood running compliance check on a dealer literally one block away from my home. It was a non-issue and took all of 45 minutes. He ran over a check list of what is required of me, asked to see my bound books, and randomly asked to see a few guns. I elected to allow him in the house rather than drag all my **** to the nearest ATF filed office an hour away in Bristol. And yes, John, CFR 478.23(c) explicitly requires them to allow me to do so. §478.23 Right of entry and examination.
(c) At the election of the licensed collector, the annual inspection permitted by this paragraph shall be performed at the ATF office responsible for conducting such inspection in closest proximity to the collectors premises. https://www.ecfr.gov/cgi-bin/text-id...se27.3.478_123

As far as them barging into your home unannounced for a compliance inspection again, no, they cannot. They can enter during business hours, but a collector is specifically not a dealer - the law is clear on that.

You are required to keep a bound book of all C&R firearms acquired or disposed of while you hold a valid 03 (C&R) FFL. It has nothing to do with whether or not you "use" your FFL. You are either a licensee or you are not a licensee - if you are a licensee you are required to record your A&D. Non-C&R firearms aren't logged, nor are firearms acquired prior to your C&R FFL unless you dispose of them while your FFL is valid. Honestly, it's no big deal.
I find the conveniences of having a C&R FFL far, far outweigh the doom and gloom John so sagely claims will befall the licensee.
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Last edited by Bill_in_VA; 04-24-2018 at 02:30 PM.
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